48 | II Série A - Número: 053S1 | 23 de Dezembro de 2014

a4
article 6 and situated in the other Contractíng State may
be taxed in that other State.
.2 — Gains from thealienation ofmovabie prõperty for
rning part ofthe business property of a
permanent estabiish
ment which an enterprise of a Contracting State has in the
other Contracting State or of movab1 property pertainiúg
to a fixed base..availabie to a residet of a ÇontraàtingState
in the other Contracting Statë for the purpose ofperfarmirlg
independent personal services incli.ding such garis from
the alienation of such a permanent establishrnent (àione
orwith the whole enterprise) or of such fixed base, may
be taxed in that other Staté.
3 — Gains from the alienation ofships or aircraft opera
ted in international traffic or movable property pertaining
to the operation of such ships or aircraft shall he taxable
only in the Contracting State in which the place ofeffective
management of the enterprise is situated.
4 — Gains derived by a resident of a Contracting State
from the alienation of shãres or a comparable interest
deriving more than 50 per cent of their value directly or
indirectly from immovable property situated in the other
Contracting State rnay be taxed in that other State.
5 — Gains from the alienation of any property other
than that referred to in paragraphs 1, 2, 3 and 4, shall be
taxable only in the Contracting State ofwhich the alieriator
is a resident.
Article 14
Independent personal services
1 Income derived hy a resident of a Contracting State
in respect ofprofessional services or other activities ofan
independent character shall be taxable onlyin that State
unless he hasa fixed base regularly available to him in
the other Contracting State for the purpose of perfomiing
his activities. Ifhe hassuch a fixed base, theincorne may
be taxed in the other State but only so much of it as is
attributable to that fixed base.
2 —— The term «profesiona1 services» includes espe
cially independent scientific, literary, artistic, educational
or teaching activities as well as the independent acivites
ofphysicians,Iawyers, engineers, architects, dentists and
aceountants.
Articlel5
Dependent personal services
.1 — Subject to theprovisions ofarti.cles .1 ,•1 8,. 19 and
20, salaries, wages and other similar remuneratipn deri
ved by a resident of a Contracting State in respect of an
empi,oyrnent shali be taxable only in that State uiilëss the
empioyment is exercised in the other Contracting State. If
the employment is so exercised, such rernuneration as is
derived therefrom may be taxed in that other State.
2— Notwithstanding the provisions of paragraph 1, re
muneration derived by a resident of a Contracting State in
respect ofan employrnent exercised in the other Contracting
State shall be taxable only in the first-mertioned State if:
a) the recipient is presènt in the other State for a perioI
or periods not excëedingin the aggregaté 183 days in any
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