Capital Gains

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....acting State from the alienation of shares deriving more than 50 percent of their value directly or indirectly from immovable property situated in the other Contracting State may be taxed in that other State.] The following paragraph 4 of Article 9 of the MLI replaces paragraph 2 of Article 13 of this Agreement: ARTICLE 9 OF THE MLI - CAPITAL GAINS FROM ALIENATION OF SHARES OR INTERESTS O....

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.... base available to a resident of a Contracting State in the other Contracting State for the purpose of performing independent personal services, including such gains from the alienation of such a permanent establishment (alone or with the whole enterprise) or of such fixed base, may be taxed in that other State. 4. Gains derived by an enterprise of a Contracting State operating ships or aircraf....