Article 3

1. New paragraphs 4 and 5 shall be added to Article 13 "Capital Gains" of the Convention that 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 % of their value directly or indirectly from immovable property situated in the other Contracting State may be taxed in that other State.

5. Paragraph 4 shall not apply to gains derived from:

a) the alienation of shares in the course of a corporate reorganisation,

b) the alienation of shares listed on a registered stock exchange."

2. Existing paragraph 4 of Article 13 of the Convention shall be renumbered as paragraph 6 and shall be modified as follows:

"6. Gains from the alienation of any property other than that referred to in paragraphs 1 to 5, shall be taxable only in the Contracting State of which the alienator is a resident."

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	Protocol Amending the Convention Between the Government of the Russian Federation and the Government of the Republic of Austria...