Capital Gain

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..... of a permanent establishment which an enterprise of a Contracting State has in the other Contracting State or of any property, other than immovable 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 .....

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..... e only in that Contracting State. The following paragraph 4 of Article 9 of the MLI applies to Article 13 of the Convention: Article 9 Capital Gains from Alienation of Shares or Interests of Entities Deriving their Value Principally from Immovable Property 4. For purposes of the Convention, gains derived by a resident of a Contracting State from the alienation of shares or comparable interests, su .....

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