ARTICLE 12
Capital Profits
(1) Profits accrued from disposition of property assets are subject to taxation in the contracting state in which such properties exist.
(2) Profits accrued from disposition of movable properties that are owned by a permanent installation or a fixed center and profits accrued from disposition of the permanent installation itself is subject to taxes in the contracting state in which such profits arise.
(3) Profits accrued from disposition of movable assets referred to in Article 7 of this treaty are subject to taxes in the state in which the actual center of management exists.
(4) Profits accrued from disposition of any funds and assets otherwise than the above mentioned in this article are subject to taxes in the state in which such profits arise.