ARTICLE 13
Capital Gains
(1) Profits which a person resident in a Contracting State draws from the sale of immoveable property that are located in the other Contracting State can be taxed in the other State.
(2) Profits from the sale of stocks or other shares in a company whose assets-directly or indirectly-consist overwhelmingly of immoveable property in one Contracting State, can be taxed in this State.
(3) Profits from the sale of moveable property, business property of a permanent establishment are those which a business of one Contracting States owns in the other Contracting State, or that belong to a fixed establishment over which a person resident in one Contracting State disposes over for the exercise of freelance employment in the other Contracting State, including any profits that are earned in the sale of such a permanent establishment (alone or with the rests of the business) or such a fixed base, can be taxed in the other State.
(4) Profits from the sale of sea vessels or aircraft that are operated in international traffic, and of moveable assets that serve the operation of these sea vessels or aircraft, can only be taxed in the Contracting State in which the business's place of effective management is located.
(5) Profits from the sale of the assets not mentioned in Paragraphs (1) to (4) can only be taxed in the Contracting State in which the seller is resident.