(1) Gains derived by a resident of the sovereign territory of a
Contracting Party from the alienation of immovable property
situated in the sovereign territory of the other Contracting Party
may be taxed in the sovereign territory of that other Contracting
Party.
(2) Gains from the alienation of shares and similar rights in a
company, the assets of which consist – directly or indirectly –
principally of immovable property situated in the sovereign
territory of a Contracting Party, may be taxed in the sovereign
territory of that Contracting Party.
(3) Gains from the alienation of movable property forming
part of the business property of a permanent establishment
which an enterprise of a Contracting Party has in the sovereign
territory of the other Contracting Party or of movable property
pertaining to a fixed base available to a resident of the
sovereign territory of a Contracting Party in the sovereign
territory of the other Contracting Party for the purpose of
performing independent personal services, including such
gains from the alienation of such a permanent establishment
(alone or with the whole enterprise) or of such fixed base, may
be taxed in the sovereign territory of that other Contracting
Party.
(4) Gains from the alienation of ships or aircraft operated in
international traffic or movable property pertaining to the
operation of such ships or aircraft, shall be taxable only in the
sovereign territory of the Contracting Party in which the place of
effective management of the enterprise is situated.
(5) Gains from the alienation of any property other than that
referred to in paragraphs 1 to 4, shall be taxable only in the
sovereign territory of the Contracting Party of which the
alienator is a resident.
(6) Where an individual was a resident of the sovereign
territory of a Contracting Party for a period of 5 years or more
and has become a resident of sovereign territory of the other
Contracting Party, paragraph 5 shall not prevent the first-
mentioned Contracting Party from taxing under its domestic
law the capital appreciation of shares in a company resident in
the sovereign territory of the first-mentioned Contracting Party
for the period of residency of that individual in the sovereign
territory of the first-mentioned Contracting Party. In such case,
the appreciation of capital taxed in the sovereign territory of the
first-mentioned Contracting Party shall not be included in the
determination of the subsequent appreciation of capital by the
other Contracting Party.
de-north-macedonia-2010-base | BGBl. 2010 II S. 1153 | signed 2006-07-13 | published 2010-10-22 | Signed: 2006-07-13 | Gazette publication: 2010-10-22
Source form
official-publication PDF with native text layer; reader is a machine transcription
Source scope
original implementing law, bilingual base treaty and accompanying protocol; not a current consolidated text
Retrieved
2026-09-30
Text and language scope
This source supplies German and English versions. The signing clause also identifies Macedonian as authentic; that third version is NOT present in this reader. Missing here does not mean globally unavailable. Unreviewed coordinate-based machine transcription of this original source edition only. Printed line breaks, hyphens and uncertain token spacing are retained, not silently corrected. Treaty preamble, closing formula, protocol and shared signatures are separate retained assets, not part of the last article. Full supplements: /review/de-north-macedonia-2010-base/. PDF page links identify pages, not verified paragraph correspondence.
Review status
Pending human wording, completeness, source-authority, currentness, alignment and rendering review. No legal review performed.
Currentness
Original source edition; not a verified current-law consolidation. Unknown as current law. Signed 2006-07-13; consent law 2010-10-16; gazette publication 2010-10-22. Edition ID year is not a signature date. Treaty entry into force: not resolved as a single source-bound field by the retained audit. Roster general application: 2011-01-01 (not a universal tax-specific rule). Cached official article entry statements (may refer to multiple instruments): 29.11.2010, 16.01.2018. Evidence is the retained 2026-10-01 agent audit of source PDF, 2026-01-01 roster and cached official HTML, not a fresh current-law determination. Bounded agent triage, no qualified wording/alignment/legal review. No exhaustive verification of all later 2026 developments. Matching digest proves retained source identity, not legal force.
Protocols and later instruments
Printed signature protocol retained separately and not merged into articles. Later amending protocol signed 2016-11-14, entered into force 2018-01-16, general application 2019-01-01; NOT included in this base source. Tax-specific application needs review. Source implementing law expressly publishes the treaty in the corrected version resulting from the exchange of notes dated 2008-07-23. Those corrections are incorporated by the official publication, not by this reader. The separately headed exchange-of-notes document is not printed in this retained PDF; do not mistake the law reference for a complete separate notes reader. MLI application and complete later amendments, replacements or suspensions are NOT verified. No developments after the retained roster snapshot are certified. This is NOT a current consolidated instrument. Source-triage warnings: Bounded agent triage, no qualified wording/alignment/legal review. No exhaustive verification of all later 2026 developments. Matching digest proves retained source identity, not legal force. Known related/later instruments NOT included in this source (agent triage, not exhaustive): amending-protocol; signature date: 2016-11-14; entry into force: 2018-01-16; general application from: 2019-01-01; limit: Exact tax-specific application remains for protocol review.
Text language and status
en · authentic-language-transcription · machine-transcription
BGBl. 2010 II S. 1153 | de-north-macedonia-2010-base | de-north-macedonia-2010-base | BGBl. 2010 II S. 1153 | signed 2006-07-13 | published 2010-10-22 | Signed: 2006-07-13 | Gazette publication: 2010-10-22 | Article 13 | en | Pending human wording, completeness, source-authority, currentness, alignment and rendering review. No legal review performed. | /library/treaties/de-north-macedonia-2010-base/en/articles/article-13/
Source, edition and limits
Source edition
de-north-macedonia-2010-base | BGBl. 2010 II S. 1153 | signed 2006-07-13 | published 2010-10-22 | Signed: 2006-07-13 | Gazette publication: 2010-10-22
Source form
official-publication PDF with native text layer; reader is a machine transcription
Source scope
original implementing law, bilingual base treaty and accompanying protocol; not a current consolidated text
Retrieved
2026-09-30
Text and language scope
This source supplies German and English versions. The signing clause also identifies Macedonian as authentic; that third version is NOT present in this reader. Missing here does not mean globally unavailable. Unreviewed coordinate-based machine transcription of this original source edition only. Printed line breaks, hyphens and uncertain token spacing are retained, not silently corrected. Treaty preamble, closing formula, protocol and shared signatures are separate retained assets, not part of the last article. Full supplements: /review/de-north-macedonia-2010-base/. PDF page links identify pages, not verified paragraph correspondence.
Review status
Pending human wording, completeness, source-authority, currentness, alignment and rendering review. No legal review performed.
Currentness
Original source edition; not a verified current-law consolidation. Unknown as current law. Signed 2006-07-13; consent law 2010-10-16; gazette publication 2010-10-22. Edition ID year is not a signature date. Treaty entry into force: not resolved as a single source-bound field by the retained audit. Roster general application: 2011-01-01 (not a universal tax-specific rule). Cached official article entry statements (may refer to multiple instruments): 29.11.2010, 16.01.2018. Evidence is the retained 2026-10-01 agent audit of source PDF, 2026-01-01 roster and cached official HTML, not a fresh current-law determination. Bounded agent triage, no qualified wording/alignment/legal review. No exhaustive verification of all later 2026 developments. Matching digest proves retained source identity, not legal force.
Protocols and later instruments
Printed signature protocol retained separately and not merged into articles. Later amending protocol signed 2016-11-14, entered into force 2018-01-16, general application 2019-01-01; NOT included in this base source. Tax-specific application needs review. Source implementing law expressly publishes the treaty in the corrected version resulting from the exchange of notes dated 2008-07-23. Those corrections are incorporated by the official publication, not by this reader. The separately headed exchange-of-notes document is not printed in this retained PDF; do not mistake the law reference for a complete separate notes reader. MLI application and complete later amendments, replacements or suspensions are NOT verified. No developments after the retained roster snapshot are certified. This is NOT a current consolidated instrument. Source-triage warnings: Bounded agent triage, no qualified wording/alignment/legal review. No exhaustive verification of all later 2026 developments. Matching digest proves retained source identity, not legal force. Known related/later instruments NOT included in this source (agent triage, not exhaustive): amending-protocol; signature date: 2016-11-14; entry into force: 2018-01-16; general application from: 2019-01-01; limit: Exact tax-specific application remains for protocol review.
Text language and status
en · authentic-language-transcription · machine-transcription