第4條
Income or gains derived by a resident of a Contracting Party from the alienation of shares of a company deriving more than 50 per cent of its asset value directly or indirectly from immovable property situated in the other Contracting Party may be taxed in that other Party. However, this paragraph does not apply to gains derived from the alienation of shares: (a) quoted on a recognised stock exchange; or (b) alienated or exchanged in the framework of a reorganisation of a company, a merger or a similar operation; or (c) in a company deriving more than 50 per cent of its asset value from immovable property in which it carries on its business.