(1) Capital gains from the alienation of immovable property, as
defined in paragraph (2) of Article 8 may be taxed in the territory
in which such property is situated.
(2) Capital gains from the alienation of movable property
forming part of the business property of a permanent establishment
which an enterprise of one of the territories has in the other
territory, including such gains from the alienation of such a
permanent establishment (alone or together with the whole
enterprise) may be taxed in the other territory.
(3) Notwithstanding the provisions of paragraph (2) of this
Article, capital gains derived by a resident of one of the
territories from the alienation of ships and aircraft operated in
international traffic and movable property pertaining to the
operation of such ships and aircraft shall be taxable only in that
territory.
