(1) Gains derived by a resident of a Contracting State from the alienation of immovable property and situated in the other Contracting State may be taxed in that other State.
(2) Gains derived from the alienation of shares or other forms of stock forming part of the business property of an enterprise, whose assets mainly consist, directly or indirectly, of immovable property in a Contracting State, shall be taxable in that Contracting State.
(3) Gains derived from the alienation of movable property forming part of the business property of a permanent establishment that 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 gains from the alienation of such a permanent establishment (alone or together with the whole enterprise), may be taxed in that other State.
(4) Gains derived from the alienation of ships or aircraft operated in international traffic, or from the alienation of boats used for internal navigation or movable property pertaining to the operation of such ships, aircraft or boats, shall be taxable only in the Contracting State in which the place of effective management of the enterprise is situated.
(5) Gains arising from the alienation of any property, other than those referred to in paragraphs (1) through (4), shall only be taxable in the Contracting State of which the alienator is a resident.