Capital gains from alienation of shares tied to immovable property: India applies the treaty's optional allocation rule. Capital gains from alienation of shares or interests in entities deriving their value principally from immovable property are governed by a treaty rule assigning taxing rights to the State of the immovable property. India elects to apply the optional rule in Article 9(4) of the BEPS Convention and notifies that numerous existing bilateral tax agreements contain provisions corresponding to the Convention's Article 9(1), identifying each such agreement's article and paragraph.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Capital gains from alienation of shares tied to immovable property: India applies the treaty's optional allocation rule.
Capital gains from alienation of shares or interests in entities deriving their value principally from immovable property are governed by a treaty rule assigning taxing rights to the State of the immovable property. India elects to apply the optional rule in Article 9(4) of the BEPS Convention and notifies that numerous existing bilateral tax agreements contain provisions corresponding to the Convention's Article 9(1), identifying each such agreement's article and paragraph.
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