(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 including such gains from the alienation of such a permanent establishment (alone or with the whole enterprise) 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 the place of effective management of the enterprise is situated.
(4) Gains from the alienation of any property other than that referred to in paragraphs (1), (2) and (3), shall be taxable only in the Contracting State of which the alienator is a resident.
(5) In the case of an individual who was a resident of one of the Contracting States and who has become a resident of the other Contracting State the first-mentioned State may tax, according to its domestic law and notwithstanding paragraph (4), capital gains from shares or rights in a company to the extent the gains have accrued by the date of change of residence, provided such shares or rights are alienated or the individual has taken measures entailing loss of the taxation right for the first-mentioned State. If the first-mentioned State taxes the capital gains according to the preceding sentence the other State, when calculating the taxable capital gains, shall recognize the sales price as determined by the first-mentioned State as cost of acquisition.