제19921호                               관              보                 2021. 1. 18.(월요일)
                                            ARTICLE VII
        With reference of Article 13 (Capital Gains) of the Agreement:
1.      Paragraph 4 shall be deleted and replaced by the following:
“4.     Gains derived by a resident of a Contracting State from the alienation of shares of capital
stocks deriving more than 50 per cent of their value directly or indirectly from immovable
property situated in the other Contracting State may be taxed in that other State.”
2.      Paragraph 5 shall be deleted and replaced by the following:
“5.     Gains from the      alienation of shares other than those mentioned in paragraph 4
representing a participation of at least 15 per cent in a company which is a resident of a
Contracting State may be taxed in that State.”
3.      A new paragraph 6 shall be inserted as follows:
“6.     Gains from the alienation of any property other than that referred to in paragraphs 1, 2,
3, 4 and 5 shall be taxable only in the State of which the alienator is a resident.”
                                           ARTICLE VIII
        With reference to Article 24 (Non-discrimination):
1.      Paragraph 3 of Article 24 shall be deleted and replaced by the following:
“3.     Except where the provisions of Article 9, paragraph 8 of Article 11, or paragraph 6 of
Article 12 apply, interest, royalties, technical fees and other disbursements paid by an enterprise
of a Contracting State to a resident of the other Contracting State shall, for the purpose of
determining the taxable profits of such enterprise, be deductible under the same conditions as if
they had been paid to a resident of the first-mentioned State.”
2.      It is understood that, if a Contracting State hereinafter concludes or has already concluded
with any other country a tax treaty of which the non-discrimination provisions are less
discriminatory to a resident of the other Contracting State than the current provisions of
non-discrimination of this Agreement, the first-mentioned provisions shall be applied promptly in
place of the last-mentioned provisions.
                                            ARTICLE IX
        With reference to Article 26 (Exchange of Information):
        Paragraph 1 shall be deleted and replaced by the following:
“1.     The competent authorities of the Contracting States shall exchange such information as is
foreseeably relevant for carrying out the provisions of this Agreement or to the administration or
enforcement of the domestic laws concerning taxes of every kind and description imposed on
behalf of the Contracting State, or of their political subdivisions or local authorities, insofar as the
taxation thereunder is not contrary to the Agreement. The exchange of information is not
restricted by Articles 1 and 2. Any information received by a Contracting State shall be treated
as secret in the same manner as information obtained under the domestic laws of that State and
shall be disclosed only to persons or authorities (including courts and administrative bodies)
concerned with the assessment or collection of, the enforcement or prosecution in respect of, the
determination of appeals in relation to the taxes referred to in the first sentence, or the oversight

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