CRA indicates that Canadian land was not Treaty-exempt even where it did not generate income

CRA indicated that a non-resident individual residing in Hong Kong for the purposes of the Canada-Hong Kong Convention who disposed of Canadian land was not exempted under the Convention on the taxable capital gain notwithstanding that the property did not generate any income, stating:

[T]he reference to Article 6, "Income from Immovable Property", in Article 13, paragraph 1, of the Convention does not have the effect of reducing the scope of that paragraph.

Neal Armstrong. Summary of 4 June 2019 Internal T.I. 2018-0783441I7 F under Treaties Income Tax Conventions – Art. 13.