ARTICLE 13
Capital Gains
(1) Gains from the alienation of immovable property, as defined in paragraph 2 of Article 6, may be taxed in the Contracting State in which such property is situated.
(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 together with the whole enterprise), may be taxed in the other State. However, gains from the alienation of movable property of the kind referred to in paragraph 3 of Article 21 shall be taxable only in the Contracting State in which such movable property is taxable according to the said Article.
(3) Gains from the alienation of any property other than those mentioned in paragraph 3 of Article 12 and in paragraphs 1 and 2 of this Article shall be taxable only in the Contracting State of which the alienator is a resident.