ARTICLE 13
Capital Gains
(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 and consisting of ships, aircraft, road or railway vehicles operated by such enterprise in international traffic or of movable property pertaining to the operation of such ships, aircraft, road or railway 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), (2) and (3), shall be taxable only in the Contracting State of which the alienator is a resident.