(1) Gains derived by a resident of a Contracting State from the alienation of immovable property referred to in Article 6 and situated in the other Contracting State may be taxed in that other State.
(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 has in the other Contracting State for independent personal services, including such gains from the alienation of such a permanent establishment (alone or with the whole enterprise) or of such fixed base, may be taxed in that other State.
(3) Gains 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 the Contracting State in which is situated the place of effective management of the company .
(4) Gains from the alienation of shares of stock or other rights in a company whose assets consist primarily, directly or indirectly, of real property situated in a Contracting State or rights attaching to such immovable property, may be taxed in that State. For the purposes of this paragraph, the term "principally" with respect to the owner of real estate means the value of the assets owned by the company.
(5) Gains from the alienation of any property other than those mentioned in the preceding paragraphs shall be taxable only in the Contracting State of which the alienator is a resident.