Capital Gains

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..... blishment which an enterprise of one of the States has in the other State or of movable property pertaining to a fixed base available to a resident of one of the States in the other State for the purpose of performing independent personal services, including such gains from the alienation of such permanent establishment (alone or with the whole enterprise) or of such fixed base, may be taxed in th .....

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..... ty in which the business of the company was carried on, may be taxed in that other State. A substantial interest exists when the resident owns 25 per cent or more of the shares of the capital stock of a company.] The following paragraph 1 of Article 9 of the MLI applies with respect to paragraph 4 of Article 13 of this Convention: ARTICLE 9 OF THE MLI - CAPITAL GAINS FROM ALIENATION OF SHARES OR I .....

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..... a 10 per cent interest in the capital stock of that company, may be taxed in that other State if the alienation takes place to a resident of that other State. However, such gains shall remain taxable only in the State of which the alienator is a resident if such gains are realised in the course of a corporate organisation, reorganization, amalgamation, division or similar transaction, and the buye .....

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