租税条約における株式等の譲渡益に関する規定（断片）
令和7年11月21日|p.23
左の本文を選ぶと、右側の官報原文画像で該当箇所を照合できます。
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
3. Notwithstanding the preceding provisions of this Article, remuneration derived by
taxed in the other Contracting State if, at any time during the 365 days preceding the
a resident of a Contracting State in respect of an employment, as a member of the regular
alienation, these shares or comparable interests derived at least 50 per cent of their value
complement of a ship or aircraft, that is exercised aboard a ship or aircraft operated in
directly or indirectly from immovable property, as defined in Article 6, situated in that
international traffic, other than aboard a ship or aircraft operated solely within the other
other Contracting State, unless such shares or comparable interests are traded on a
Contracting State, shall be taxable only in the first-mentioned Contracting State.
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