Article 13(4) of the OECD Model Convention: CGT on Alienation of Shares in Immovable Property Companies: Part I

In this two-part article we consider the taxation of capital gains deriving from the alienation of shares in immovable property companies. In part I we consider in detail: the object of the investigation; the definition of "immovable property"; taxation of income deriving from immovable property and the interrelationship between Articles 6, 7 and 21; and the taxation of capital gains according to Article 13.