Common use of GAINS FROM THE ALIENATION OF PROPERTY Clause in Contracts

GAINS FROM THE ALIENATION OF PROPERTY. 1. Gains from the alienation of immovable property, as defined in Article 6, may be taxed in the Contracting State in which such property is situated. 2. Gains from the alienation of movable property forming part of the business property of a permanent establishment which an enterprise 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 with the whole enterprise) or of such fixed base, may be taxed in that other State. 3. Gains from the alienation of ships or aircraft operated by an enterprise of a Contracting State in international traffic or movable property pertaining to the operation of such ships or aircraft, shall be taxable only in that Contracting State. 4. Gains derived by a resident of a Contracting State from the alienation of shares in a company, the assets of which consist wholly or principally or immovable property situated in the other Contracting State, may be taxed in that other State. 5. Gains from the alienation of shares other than those mentioned in paragraph 4 in a company which is a resident of a Contracting State may be taxed in that State. 6. Gains from the alienation of any property other than that referred to in paragraphs 1, 2, 3, 4 and 5 shall be taxable only in the Contracting State of which the alienator is a resident.

GAINS FROM THE ALIENATION OF PROPERTY. 1. Gains from the alienation of immovable property, as defined in Article 6, may be taxed in the Contracting State in which such property is situated. 2. Gains from the alienation of movable property forming part of the business property of a permanent establishment which an enterprise 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 with the whole enterprise) or of such fixed base, may be taxed in that other State. 3. Gains from the alienation of ships or aircraft operated by an enterprise of a Contracting State in international traffic or movable property pertaining to the operation of such ships or aircraft, shall be taxable only in that Contracting State. 4. Gains derived by a resident of a Contracting State from the alienation of shares or comparable interests in a company, the assets of which consist wholly or principally or of immovable property situated in the other Contracting State, may be taxed in that other State. 5. Gains from the alienation of shares other than those mentioned in paragraph 4 in a company which is a resident of a Contracting State may be taxed in that State. 6. Gains from the alienation of any property other than that referred to in paragraphs 1, 2, 3, 4 and 5 shall be taxable only in the Contracting State of which the alienator is a resident.

GAINS FROM THE ALIENATION OF PROPERTY. 1. Gains derived by a resident of a Contracting State from the alienation of immovable property, as defined property referred to in Article 66 and situated in other Contracting State may be taxed in that other State. 2. Gains derived by a resident of a Contracting State from the alienation of: a) shares, other than shares quoted on an approved Stock Exchange, deriving their value or the greater part of their value directly or indirectly from immovable property situated in the other Contracting State, or b) an interest in the assets of a person other than an individual where such assets consist principally of immovable property situated in the other Contracting State or of shares referred to in sub-paragraph (a) above, may be taxed in the Contracting State in which such property is situatedthat other State. 23. Gains from the alienation of movable property forming part of the business property of a permanent establishment which an enterprise 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 with the whole enterprise) or of such fixed base, may be taxed in that other State. 34. Gains from the alienation of ships ships, aircraft, railway or aircraft road transport vehicles operated in international transport by an enterprise of a Contracting State in international traffic or of movable property pertaining to the operation of such ships or aircraft, the mentioned means of transport shall be taxable only in that Contracting State. 4. Gains derived by a resident of a Contracting State from the alienation of shares in a company, the assets of which consist wholly or principally or immovable property situated in the other Contracting State, may be taxed in that other State. 5. Gains from the alienation of shares other than those mentioned in paragraph 4 in a company which is a resident of a Contracting State may be taxed in that State. 6. Gains from the alienation of any property other than that referred to in paragraphs 1, 2, 3, 3 and 4 and 5 of this Article shall be taxable only in the Contracting State of which the alienator is a resident.

GAINS FROM THE ALIENATION OF PROPERTY. 1. Gains from the alienation alimentation of immovable property, as defined in Article 6, may be taxed in the Contracting State in which such property is situated. 2. Gains from the alienation of movable property forming part of the business property of a permanent establishment which an enterprise 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 with the whole enterprise) or of such fixed base, may be taxed in that other State. 3. Gains from the alienation of ships or aircraft operated by an enterprise of a Contracting State in international traffic or movable property pertaining to the operation of such ships or aircraft, shall be taxable only in that the Contracting StateState in which the place of effective management of the enterprise is situated. 4. Gains derived by a resident of a Contracting State from the alienation of shares or comparable interests in a company, company or trust the assets of which consist wholly or principally or immovable property situated in the other Contracting State, may be taxed in that other State. 5. Gains from the alienation of shares other than those mentioned in paragraph 4 in a company or trust which is a resident of a Contracting State may be taxed in that State. 6. Gains from the alienation of any property other than that referred to in paragraphs 1, 2, 3, 4 and 5 shall be taxable only in the Contracting State of which the alienator is a resident.

GAINS FROM THE ALIENATION OF PROPERTY. 1. Gains derived by a resident of a Contracting State from the alienation of immovable property, as defined property referred to in Article 6, 6 and situated in the other Contracting State may be taxed in the Contracting State in which such property is situatedthat other State. 2. Gains from the alienation of movable property forming part of the business property of a permanent establishment which an enterprise 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 professional services, including such gains from the alienation of such a permanent establishment (alone or together with the whole enterprise) or of such fixed base, may be taxed in that other State. 3. Gains from the alienation of ships or aircraft operated by an enterprise of a Contracting State in international traffic or and movable property pertaining to the operation of such ships or aircraft, aircraft shall be taxable only in that Contracting Statethe State of which the enterprise is a resident. 4. Gains derived by a resident of a Contracting State from the alienation of stocks and shares in of a company, company representing a participation of 25 per cent or more of the assets issued capital of which consist wholly or principally or immovable property situated in the other Contracting State, that company may be taxed in that other Statethe Contracting State in which they have been issued. 5. Gains from the alienation of shares other than those mentioned in paragraph 4 in a company which is a resident of a Contracting State may be taxed in that State. 6. Gains from the alienation of any property or assets, other than that referred to in paragraphs 1, 2, 3, 3 and 4 and 5 shall be taxable only in the Contracting State of which the alienator is a resident.

GAINS FROM THE ALIENATION OF PROPERTY. 1. Gains from the alienation of immovable property, as defined in Article 6, may be taxed in the Contracting State in which such property is situated. 2. Gains from the alienation of movable property forming part of the business property of a permanent establishment which an enterprise 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 with the whole enterprise) or of such fixed base, may be taxed in that other State. 3. Gains from the alienation of ships or aircraft operated by an enterprise of a Contracting State in international traffic or movable property pertaining to the operation of such ships or aircraft, shall be taxable only in that Contracting StateState of which the enterprise is a resident. 4. Gains derived by a resident of a Contracting State from the alienation of shares or comparable interests in a company, the assets of which consist wholly or principally or of immovable property situated in the other Contracting State, may be taxed in that other State. 5. Gains from the alienation of shares other than those mentioned in paragraph 4 in a company which is a resident of a Contracting State may be taxed in that other State. 6. Gains from the alienation of any property other than that referred to in paragraphs 1, 2, 3, 4 1,2,3,4 and 5 shall be taxable only in the Contracting State of which the alienator is a resident.