(1) Gains derived by a resident of a Contracting State from
the alienation of immovable property referred to in Article 6 and
situated in the other Contracting State may be taxed in that
other State.
(2) Gains derived by a resident of a Contracting State from
the alienation of shares and similar rights in a company, the
assets of which derive at least 75 per cent of their value
directly or indirectly from immovable property situated in the
other Contracting State may be taxed in that other State. This
shall not apply to shares traded on a recognised Stock
Exchange.
(3) Gains from the alienation of movable property forming
part of the business property of a permanent establishment
which an enterprise of a Contracting State has in the other Con-
tracting State or of movable property pertaining to a fixed base
available to a resident of a Contracting State in the other Con-
tracting State for the purpose of performing independent per-
sonal 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 that other State.
(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
Contracting State 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 above shall be taxable only in
the Contracting State of which the alienator is a resident.
(6) Where an individual was a resident of a Contracting State
for a period of 5 years or more and has become a resident of the
other Contracting State, paragraph 5 above shall not prevent
the first-mentioned State from taxing under its domestic law the
capital appreciation of shares in a company resident in the first-
mentioned State for the period of residency of that individual in
the first-mentioned State. Where the first-mentioned Contract-
ing State has taxed the appreciation of capital pursuant to the
first sentence, this appreciation of capital shall not be included
in the determination of the subsequent appreciation of capital
by the other Contracting State.
de-singapore-2006-base | BGBl. 2006 II S. 930 | Signed: 2004-06-28 | Gazette publication: 2006-11-03
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
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-singapore-2006-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. No current-law consolidation, effective-period determination, MLI application, or complete amendment-chain verification has been performed. Original publication year is not a current applicability date. Original signed-2004/published-2006 edition omits the 2019 amendment and 2021 notification ordinance. Not listed in roster I.2; this is snapshot evidence only, not proof of no MLI relevance forever.
Protocols and later instruments
The protocol printed with this agreement is separately preserved in source supplements; it has not been merged into treaty articles. Subsequent protocols, amendments, MLI effects, replacements and suspensions are unresolved. This is not a consolidated current-law instrument. Source-triage warnings: Original signed-2004/published-2006 edition omits the 2019 amendment and 2021 notification ordinance. Not listed in roster I.2; this is snapshot evidence only, not proof of no MLI relevance forever. Known related/later instruments NOT included in this source (agent triage, not exhaustive): amending-protocol; signature date: 2019-12-09; citation: BGBl. 2020 II S. 1178; BGBl. 2021 II S. 437; entry into force: 2021-03-29; general application: 2022-01-01 / domestic-notification-ordinance; citation: BGBl. 2021 I S. 5218; entry into force: 2021-12-23
Text language and status
en · authentic-language-transcription · machine-transcription
BGBl. 2006 II S. 930 | de-singapore-2006-base | de-singapore-2006-base | BGBl. 2006 II S. 930 | Signed: 2004-06-28 | Gazette publication: 2006-11-03 | Article 13 | en | Pending human wording, completeness, source-authority, currentness, alignment and rendering review. No legal review performed. | /library/treaties/de-singapore-2006-base/en/articles/article-13/
Source, edition and limits
Source edition
de-singapore-2006-base | BGBl. 2006 II S. 930 | Signed: 2004-06-28 | Gazette publication: 2006-11-03
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
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-singapore-2006-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. No current-law consolidation, effective-period determination, MLI application, or complete amendment-chain verification has been performed. Original publication year is not a current applicability date. Original signed-2004/published-2006 edition omits the 2019 amendment and 2021 notification ordinance. Not listed in roster I.2; this is snapshot evidence only, not proof of no MLI relevance forever.
Protocols and later instruments
The protocol printed with this agreement is separately preserved in source supplements; it has not been merged into treaty articles. Subsequent protocols, amendments, MLI effects, replacements and suspensions are unresolved. This is not a consolidated current-law instrument. Source-triage warnings: Original signed-2004/published-2006 edition omits the 2019 amendment and 2021 notification ordinance. Not listed in roster I.2; this is snapshot evidence only, not proof of no MLI relevance forever. Known related/later instruments NOT included in this source (agent triage, not exhaustive): amending-protocol; signature date: 2019-12-09; citation: BGBl. 2020 II S. 1178; BGBl. 2021 II S. 437; entry into force: 2021-03-29; general application: 2022-01-01 / domestic-notification-ordinance; citation: BGBl. 2021 I S. 5218; entry into force: 2021-12-23
Text language and status
en · authentic-language-transcription · machine-transcription