Capital gains

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..... 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 together with the whole enterprise) or of such a fixed b .....

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..... e State of residence of the company whose shares are being alienated ; and] 2 [4. Gains from the alienation of any property other than that referred to in paragraphs 1, 2, 3 and 3A shall be taxable only in the Contracting State of which the alienator is a resident.] 5. For the purposes of this article, the term alienation means the sale, exchange, transfer, or relinquishment of the proper .....

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