TMI BlogCapital gainsX X X X Extracts X X X X X X X X Extracts X X X X ..... of a permanent establishment which an enterprise of a Contracting State has in the other Contracting State or of movable 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 (alone or together with the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... raph 4 representing a participation of at least 10 per cent in a company which is a resident of a Contracting State may be taxed in that Contracting State. 6. Gains from the alienation of any property other than that mentioned in paragraphs 1, 2, 4 and 5 shall be taxable only in the Contracting State of which the alienator is a resident. - - statute, statutory provisions legislation, law, ena ..... X X X X Extracts X X X X X X X X Extracts X X X X
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