(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 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 property forming part of the business property of an enterprise and consisting of ships or aircraft operated by such enterprise in international traffic or of 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 or other interests in a company deriving more than 50 per cent of their value directly or indirectly from immovable property situated in the other Contracting State, other than immovable property in which that company carries on its business, may be taxed in that other Contracting State.

(5) Notwithstanding the provisions of paragraph (4), gains derived by a resident of a Contracting State from the alienation of shares or other interests in a company which is a resident of the other 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) and (5), shall be taxable only in the Contracting State of which the alienator is a resident.