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Note: This Treaty may be impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). MLI impact on Tax Treaties is available with the Orbitax International Tax Research & Compliance Expert.

ARTICLE 13

Capital Gains

(1) Gains derived by a resident of a Contracting State from the alienation of immovable property, as defined in paragraph 2 of Article 6, and situated in the other Contracting State 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, including such gains from the alienation of such a permanent establishment (alone or together with the whole enterprise), may be taxed in that other State.

(3) Gains from the alienation of ships or aircraft operated in international traffic and movable property pertaining to the operation of such ships or aircraft, shall be taxable only in the Contracting State 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 of companies that are listed on an approved Stock market shall be taxable only in the State of residence.

(5) Gains from the alienation of any movable property other than that referred to in paragraphs 2, 3 and 4, such as shares in a company, other than those mentioned in paragraph 4, or securities, bonds, debentures and the like, shall be taxable only in the Contracting State of which the alienator is a resident.