ALIENATION OF PROPERTY. 1. Income or gains derived by a resident of a Contracting State from the alienation of immovable property referred to in Article 6 and situated in the other Contracting State may be taxed in that other State.
ALIENATION OF PROPERTY. 1. Income, profits or gains derived by a resident of a Contracting State from the alienation of real property situated in the other Contracting State may be taxed in that other State.
ALIENATION OF PROPERTY. 1 Income, profits or gains derived by a resident of a Contracting State from the alienation of immovable property referred to in Article 6 and situated in the other Contracting State may be taxed in that other State.
ALIENATION OF PROPERTY. 1. Income from the alienation of real property may be taxed in the Contracting State in which that property is situated.
ALIENATION OF PROPERTY. 1. Income from gains from the alienation of immovable property, as defined in paragraph (2) of Article 6, may be taxed in the Contracting State in which such property is situated.
ALIENATION OF PROPERTY. 1. Income or gains from the alienation of immovable property, as defined in Article 6, may be taxed in the Contracting State in which such property is situated.
ALIENATION OF PROPERTY. 1. Gains derived by a resident of a Contracting State from the alienation of real property (as defined in paragraph 2 of Article 6) situated in the other Contracting State may be taxed in that other State.
ALIENATION OF PROPERTY. 1. Where a gain or loss of a capital nature accrues to or is incurred by an individual who is a resident of a Contracting State, from the alienation of property situated in Area A or shares or comparable interests in a company, the assets of which consist wholly or principally of property situated in Area A, the amount of the gain or loss shall be taxable, or otherwise recognised for taxation purposes, only in that Contracting State.
ALIENATION OF PROPERTY. ARTICLE Most of Australia's DTAs contain an equivalent to Art 13 of the OECD Convention which refers to gains derived from the "alienation of immovable property". This is usually the only article specifically referring to capital gains. Parts 5.1 to 5.4 (which follow) illustrate the different versions of Art 13 in Australia's DTAs. Some contain no equivalent of the article at all. Others can potentially apply but only within prescribed circumstances. More recent DTAs show a clear intention to determine taxing rights regarding capital gains from the disposal of shares.
ALIENATION OF PROPERTY. Where a gain or loss of a capital nature accrues to or is incurred by an individual who is a resident of a Contracting State, from the alienation of property situated in Area A or shares or comparable interests in a company, the assets of which consist wholly or principally of property situated in Area A, the amount of the gain or loss shall be taxable, or otherwise recognised for taxation purposes, only in that Contracting State. Where a gain or loss of a capital nature accrues to or is incurred by a person, other than an individual who is a resident of a Contracting State, from the alienation of property situated in Area A or shares or comparable interests in a company, the assets of which consist wholly or principally of property situated in Area A, the amount of the gain or loss shall, for the purposes of the law of a Contracting State, be an amount equivalent to fifty (50) per cent of the amount that would be the gain or loss but for this paragraph.
