Capital gains taxation: treaty amended to allow source-state taxation for later-acquired shares with transitional relief, subject to anti abuse safeguards. Article 9 requires appropriate transfer pricing adjustments and inter-competent authority consultation where one State includes in profits amounts charged to tax in the other State. Article 13 distinguishes capital gains taxation for shares by date of acquisition-pre-amendment gains taxable only in the alienator's residence while later-acquired share gains may be taxed in the company's residence subject to a limited transitional reduced source-state tax concession. A new anti abuse Article denies treaty benefits for arrangements whose primary purpose is to obtain the capital gains benefits and for shell or conduit companies unless listed or meeting substance expenditure thresholds.