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 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 fixed base, may be taxed in that other State. 

3. Gains derived by an enterprise of a Contracting State 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 that State. 

4. Gains from the alienation of any property other then that referred to in  paragraphs 1, 2 and 3, shall be taxable only in the Contracting State of which the  alienator is a resident.