Profits from Alienation of Property
(1) Profits 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) Profits from the alienation of stocks and other shares in the participation of a company whose assets consist primarily of immovable property situated in a Contracting State may be taxed in that State.
(3) Profits 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.
(4) Profits from the alienation of ships or aircraft operated in international traffic and ships intended for inland water transport, as well as movable property intended for the operation of such ships or aircraft, may be taxed in only the Contracting State in which the place of effective management of the enterprise is situated.
(5) Profits from the alienation of property not designated in paragraphs (1) through 4 of this Article may be taxed in only the Contracting State of which the person alienating the property is a resident.
(6) With respect to an individual who was a resident of a Contracting State for at least five years and has become a resident of the other Contracting State, the provisions of paragraph (5) of this Article shall not affect the right of the first-mentioned State to subject the capital gains of the aforementioned individual in respect of shares of participation in companies to taxation in accordance with its domestic legal acts until the individual has changed his place of residence. If the first-mentioned Contracting State taxes the capital gains in the event that a resident moves away, then, in the event of later alienation of the shares, if the profit gained therefrom is taxed in the other State in accordance with paragraph (5), that State, in ascertaining the profits from alienation, will assume as a basis for acquisition costs the amount that the first-mentioned State has assumed as revenue at the time of the move.