“Gains from the alienation of shares acquired on or after April 1, 2017 in a company which is a resident of a Contracting State may be taxed in that State,” it states.
But the rate of tax will be not more than 50 per cent of the prevalent capital gains tax in first two years – ie from April 1, 2017 to March 31, 2019.
Gains from the alienation of any property other than shares and profits made shall be taxable only in the country of which the alienator is a resident.
