With reference to Article 13 (Capital Gains). For purposes of subparagraph b) of paragraph 6 of Article 13, the terms “mutual fund” and “institutional investor” shall not include an investor of a Contracting State which directly or indirectly owns 10 percent or more of the shares or other rights representing the capital or of the profits in a company of the other Contracting State.
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Samples: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
With reference to Article 13 (Capital Gains). For purposes of subparagraph b) of paragraph 6 of Article 13, the terms “mutual fund” mutual fund and “institutional investor” institutional investor shall not include an investor of a Contracting State which directly or indirectly owns 10 percent or more of the shares or other rights representing the capital or of the profits in a company of the other Contracting State.
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