Article 13 - Capital Gain

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....the alienation of such a permanent establishment (alone or with the whole enterprise), may be taxed in that other State. [ Para 2 of Article 13 ] * Capital gain from transfer of ships or aircraft * Gains that an enterprise of a Contracting State that operates ships or aircraft in international traffic derives from the alienation of such ships or aircraft, or of movable property pertaining to the operation of such ships or aircraft, shall be taxable only in that State. [ Para 3 of Article 13 ] * Capital gain from transfer of interest or share * Gains derived by a resident of a Contracting State from the alienation of shares or comparable interests, * such as interests in a partnership or trust, may be taxed in the other Contracti....

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....trust * Gains derived by a resident of a Contracting State from the alienation of shares or comparable interests, such as interests in a partnership or trust, may be taxed in the other Contracting State * if these shares or comparable interests derived more than 50 per cent of their value directly or indirectly from immovable property, as defined in Article 6, situated in that other State, * at any time during the 365 days preceding the alienation. [ Para 4 of Article 13 ] * Gains, other than those to which paragraph 4 applies, derived by a resident of a Contracting State from the alienation of shares of a company, or comparable interests, such as interests in a partnership or trust, which is a resident of the other Contracting St....