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Note: This Treaty may be impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). MLI impact on Tax Treaties is available with the Orbitax International Tax Research & Compliance Expert.

ARTICLE 13

Income from Alienation of Property

(1) Income derived by a person with permanent residency in a Contracting State from the alienation of immovable property situated in the other Contracting State may be taxed in that other Contracting State.

(2) Income derived by a person with permanent residency in a Contracting State from the alienation of movable property forming part of the commercial property of his permanent establishment in the other Contracting State, or forming part of movable property pertaining to a fixed base available to that person for the purposes of conducting independent personal activities, including also income from the alienation of such permanent establishment (separately or together with the person that created it), or of such fixed base, may be taxed in that other Contracting State.

(3) Income derived from the alienation of conveyances used in international traffic by a person with permanent residency in a Contracting State, or from movable property pertaining to the operation of such conveyances, shall be taxable only in the State in which the person alienating the property has permanent residency.

(4) Income derived from the alienation of any property other than that referred to in paragraphs (1), (2) and (3) of this article shall be taxable only in the Contracting State in which the person alienating the property has permanent residency.