Capital gains

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..... blishment which an enterprise of a Contracting State has in the other Contracting State or of movable property pertaining to a fixed 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 together with the whole enterprise) or .....

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..... Contracting State of which the alienator is a resident. ----------------------- NOTES:- 1 . Substituted vide Notification No. 47/2014 dated 24 September, 2014 before it was read as, 4. Gains from the alienation of shares of the capital stock of a company the property of which consists directly or indirectly principally of immovable property situated in a Contracting State may be taxed in that Stat .....

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