Gains from the Alienation of Property
(1) Gains derived by a resident of a Contracting State from the alienation of immovable property referred to in Article 6 and situated in the other Contracting State may be taxed in that 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, including such gains from the alienation of such a permanent establishment (alone or with the whole enterprise), may be taxed in that other State.
(3) Gains from the alienation of property forming part of the business property of an enterprise consisting of ships, boats, and aircraft, railway or road vehicles operated in international traffic by said enterprise, or by movable property pertaining to the operation of such ships, boats, aircraft, railway or road vehicles, shall be taxable only in the Contracting State in which the place of effective management of the enterprise is situated.
(4) Gains from the alienation of any property other than that referred to in paragraphs (1) to (3), shall be taxable only in the Contracting State of which the alienator is a resident.