ARTICLE I

1. A new paragraph 4 shall be added to Article 13 ("Capital Gains") of the Convention, which shall read as follows:

"4. Gains derived by a resident of a Contracting State from the alienation of shares or similar rights in a company deriving more than 50 % of their value directly or indirectly from immovable property situated in the other Contracting State may be taxed in that other State.

The provisions of this paragraph shall not apply to gains derived from:

a) the alienation of shares or similar rights in a company, in the course of a corporate reorganisation, or

b) the alienation of shares or similar rights in a company, listed on a recognized stock exchange, or

c) the alienation of shares or similar rights in a company, deriving more than 50 % of its value from immovable property in which it carries on its business.

For the purposes of this paragraph, the term "recognised stock exchange" means:

(i) any regulated market pursuant to the Directive 2014/65/EU of the European Parliament and of the Council of 15 May 2014 on markets in financial instruments and amending Directive 2002/92/EC and Directive 2011/61/EU (as amended) or any successor Directive;

(ii) Moscow Exchange (MOEX) and any stock exchange established and regulated as such under the laws of the Russian Federation;

(iii) the NASDAQ system, the New York Stock Exchange, Six Swiss Exchange;

(iv) any other stock exchange that the competent authorities of the Contracting States agree to recognise for the purposes of this paragraph."

2. The existing paragraph 4 of Article 13 of the Convention shall be renumbered as paragraph 5 and shall be replaced by the following:

"Gains from the alienation of any property other than that referred to in paragraphs 1 to 4 shall be taxable only in the Contracting State of which the alienator is a resident.".

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