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Article VIII

Article VIII

 

1. Paragraph 4 of Article 13 (Income from the increment of the value of property) of the Convention shall be renumbered as paragraph 5.

2. A new paragraph 4 shall be added to Article 13 (Income from the increment of the value of property) 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 deriving more than 50 per cent of their value directly or indirectly from immovable property situated in the other Contracting State may be taxed in that other State."

3. The reference in paragraph 5, as renumbered, of Article 13 (Income from the increment of the value of property) of the Convention to "paragraphs 1, 2 and 3" shall be deleted and replaced by a reference to "paragraphs 1, 2, 3 and 4".