ARTICLE 13
Capital Gains
(1) Gains that a resident of a Contracting State derives from the alienation of immovable property as defined in paragraph (2) of Article 6 shall be taxable in the Contracting State where 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 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 such gains from the alienation of such a permanent establishment (alone or with the whole enterprise) of such fixed base, may be taxed in that other State. However, gains from the alienation of the movable property described in paragraph (3) of Article 23 may be taxed only in the Contracting State in which the property in question may be taxed under said Article.
(3) Gains from the alienation of any property other than those referred to in paragraphs (1) and (2) shall be taxable only in the Contracting State of which the alienator is a resident.