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        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.

        <h1>Source-based taxation of capital gains enables the source jurisdiction to tax gains, with grandfathering and expanded PE rules.</h1> The revised treaty shifts taxation of capital gains on share transfers to source-based taxation, with a Protocol grandfathering clause excluding shares acquired before a specified cutoff; it also subjects gains from shares of companies whose principal assets are immovable property in a Contracting State to source taxation.

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