租税条約：財産の譲渡による所得（Article 20）
令和7年10月31日|p.28
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2. Gains from the alienation of any property, other than immovable property referred
to in Article 6, forming part of the business property of a permanent establishment which
an enterprise of a Contracting State has in the other Contracting State, including such
gains from the alienation of such a permanent establishment (alone or with the whole
enterprise), may be taxed in that other Contracting State.
3. Gains that an enterprise of a Contracting State that operates ships or aircraft in
international traffic derives from the alienation of such ships or aircraft, or of any property
other than immovable property referred to in Article 6, pertaining to the operation of such
ships or aircraft, shall be taxable only in that Contracting State.
4. Gains derived by a resident of a Contracting State from the alienation of shares of
a company or comparable interests, such as interests in a partnership or trust, may be
taxed in the other Contracting State if, at any time during the 365 days preceding the
alienation, these shares or comparable interests derived at least 50 per cent of their value
directly or indirectly from immovable property, as defined in Article 6, situated in that
other Contracting State, unless such shares or comparable interests are traded on a
recognised stock exchange specified in subparagraph (b) of paragraph 4 of Article 28 and
the resident and persons related to that resident own in the aggregate 5 per cent or less of
the class of such shares or comparable interests.
5. Gains from the alienation of any property, other than that referred to in paragraphs
1, 2, 3 and 4, shall be taxable only in the Contracting State of which the alienator0.00.0
resident.