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ARTICLE 13

U.S. Income Tax Treaty — estonia tax treaty documents: estonia.pdf · 2026-10-03 edition · updated 2026-10-04 · United States

Capital Gains

  1. Gains or income derived by a resident of a Contracting State from the alienation of immovable (real) property situated in the other Contracting State may be taxed in that other State.

  2. For the purposes of this Article, the term "immovable (real) property situated in the other Contracting State" includes immovable (real) property referred to in Article 6 (Income from Immovable (Real) Property) which is situated in that other State. It also includes shares of stock of a company the property of which consists at least 50 percent of immovable (real) property situated in that other State, and an interest in a partnership, trust or estate to the extent that its assets consist of immovable (real) property situated in that other State. In the United States the term includes a "United States real property interest."

  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 Contracting State, or of movable property pertaining to a fixed base which is available to a resident of a Contracting State in the other Contracting State 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 fixed base, may be taxed in that other State.

  4. Gains derived by an enterprise of a Contracting State operating ships or aircraft in international traffic from the alienation of ships, aircraft or containers operated or used in international traffic or movable property pertaining to the operation or use of such ships, aircraft or containers shall be taxable only in that State.

  5. Payments described in paragraph 3 of Article 12 (Royalties) shall be taxable only in accordance with the provisions of Article 12.

  6. Gains from the alienation of any property other than property referred to in paragraphs 1 through 5 shall be taxable only in the Contracting State of which the alienator is a resident.

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▸Contents — U.S. Income Tax Treaty — estonia tax treaty documents: estonia.pdf
U.S. Income Tax Treaty — estonia tax treaty documents: estonia.pdf

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