(1) Gains derived by a resident of a territory from the alienation of immovable property situated in the other territory may be taxed in that other territory.
(2) Gains from the alienation of shares and similar rights in a company, the assets of which consist-directly or indirectly-principally of immovable property situated in a territory, may be taxed in that territory.
(3) Gains from the alienation of movable property forming part of the business property of a permanent establishment which an enterprise of a territory has in the other territory, including such gains from the alienation of such a permanent establishment (alone or with the whole enterprise), may be taxed in that other territory.
(4) Gains derived by an enterprise of a territory from the alienation of ships or aircraft operated in international traffic, or movable property pertaining to the operation of such ships or aircraft, shall be taxable only in that territory.
(5) Gains from the alienation of any property other than that referred to in paragraphs 1 to 4, shall be taxable only in the territory of which the alienator is a resident.
(6) Where an individual was a resident of a territory for a period of five years or more and has become a resident of the other territory, paragraph 5 shall not prevent the first-mentioned territory from taxing under its domestic law the capital appreciation of shares in a company resident in the first-mentioned territory for the period of residency of that individual in the first-mentioned territory. In such case, the appreciation of capital taxed in the first-mentioned territory shall not be included in the determination of the subsequent appreciation of capital by the other territory.