Capital Gains

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....rise of a Contracting State has in the other Contracting State or of movable property pertaining to a fixed base available to a resident of a Contracting State in the other Contracting State for the purpose of performing independent personal services, including such gains from the alienation of such a permanent establishment (alone or together with the whole enterprise) or of such a fixed base, ma....

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....nce of the company whose shares are being alienated"; and] 2[4. Gains from the alienation of any property other than that referred to in paragraphs 1, 2, 3 and 3A shall be taxable only in the Contracting State of which the alienator is a resident.] 5. For the purposes of this article, the term "alienation" means the sale, exchange, transfer, or relinquishment of the property or the ext....