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Double Taxation: OECD Model Convention
- 1.
- Gains derived by a resident of a Contracting State from the alienation
of immovable property referred to in Article 6 and situated in the other
Contracting State may be taxed in that other State.
- 2.
- Gains from the alienation of movable property forming part of the
business property of a permanent establishment which an enterprise of a
Contracting State has in the other Contracting State, including such gains
from the alienation of such a permanent establishment (alone or with the
whole enterprise), may be taxed in that other State.
- 3.
- Gains from the alienation of ships or aircraft operated in
international traffic, boats engaged in inland waterways transport or
movable property pertaining to the operation of such ships, aircraft or
boats, shall be taxable only in the Contracting State in which the place of
effective management of the enterprise is situated.
- 4.
- Gains derived by a resident of a Contracting State from the alienation
of shares deriving more than 50 per cent of their value directly or
indirectly from immovable property situated in the other Contracting State
may be taxed in that other State.
- 5.
- Gains from the alienation of any property, other than that referred to
in paragraphs 1, 2, 3 and 4, shall be taxable only in the Contracting State
of which the alienator is a resident.
[Article 14 - INDEPENDENT PERSONAL SERVICES]
[Deleted]
© OECD: Last modified: 2003-04-09
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