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Capital Gains

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..... 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) or of such a fixed base, may be taxed in that .....

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..... ontracting State from the alienation, directly or indirectly, of shares or other rights representing the capital of a company that is a resident of the other Contracting State, other than those mentioned in paragraph 4 may be taxed in that other Contracting State. 6. Gains from the alienation of any property, other than that referred to in paragraphs 1, 2, 3, 4 and 5, shall be taxable only in the .....

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