9911796707
TMI BlogCapital Gains from Alienation of Shares or Interests of Entities Deriving their Value Principally from Immovable PropertyX X X X Extracts X X X X X X X X Extracts X X X X ..... Property 1. Provisions of a Covered Tax Agreement providing that gains derived by a resident of a Contracting Jurisdiction from the alienation of shares or other rights of participation in an entity may be taxed in the other Contracting Jurisdiction provided that these shares or rights derived more than a certain part of their value from immovable property (real property) situated in that other C ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... espect to its Covered Tax Agreements. 4. For purposes of a Covered Tax Agreement, gains derived by a resident of a Contracting Jurisdiction from the alienation of shares or comparable interests, such as interests in a partnership or trust, may be taxed in the other Contracting Jurisdiction if, at any time during the 365 days preceding the alienation, these shares or comparable interests derived mo ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... to apply to its Covered Tax Agreements; b) for subparagraph a) of paragraph 1 not to apply to its Covered Tax Agreements; c) for subparagraph b) of paragraph 1 not to apply to its Covered Tax Agreements; d) for subparagraph a) of paragraph 1 not to apply to its Covered Tax Agreements that already contain a provision of the type described in paragraph 1 that includes a period for determining wheth ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tion with respect to that provision. 8. Each Party that chooses to apply paragraph 4 shall notify the Depositary of its choice. Paragraph 4 shall apply to a Covered Tax Agreement only where all Contracting Jurisdictions have made such a notification. In such case, paragraph 1 shall not apply with respect to that Covered Tax Agreement. In the case of a Party that has not made the reservation descri ..... X X X X Extracts X X X X X X X X Extracts X X X X
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