2.It is hereby declared— (a) that the arrangements specified in...
Article 5 Permanent establishment
1.For the purposes of this Convention, the term “permanent establishment”...
2.The term “permanent establishment” includes especially: (a) a place of...
3.A building site, a construction, assembly or installation project constitutes...
4.Notwithstanding the preceding provisions of this Article, the term “permanent...
5.Notwithstanding the provisions of paragraphs (1) and (2) of this...
1.The profits of an enterprise of a Contracting State shall...
2.Subject to the provisions of paragraph (3) of this Article,...
3.In determining the profits of a permanent establishment, there shall...
4.No profits shall be attributed to a permanent establishment by...
5.For the purposes of the preceding paragraphs, the profits to...
6.Where profits include items of income or capital gains which...
2.However, such interest may also be taxed in the Contracting...
3.Notwithstanding the provisions of paragraph (2) of this Article interest...
4.The term “interest” as used in this Article means income...
6.Interest shall be deemed to arise in a Contracting State...
7.Where by reason of a special relationship between the payer...
2.However, such royalties may also be taxed in the Contracting...
3.The term “royalties” as used in this Article means payments...
4.The provisions of paragraphs (1) and (2) of this Article...
5.Royalties shall be deemed to arise in a Contracting State...
6.Where, by reason of a special relationship between the payer...
1.Gains derived by a resident of a Contracting State from...
2.Gains derived by a resident of a Contracting State from...
3.Gains from the alienation of movable property forming part of...
4.Gains derived by an enterprise of a Contracting State from...
5.Gains from the alienation of any property other than that...
6.The provisions of paragraph (5) of this Article shall not...
Article 23 Miscellaneous rules applicable to certain Offshore Activities
1.The provisions of this Article shall apply notwithstanding any other...
2.In this Article the term “offshore activities” means activities which...
3.An enterprise of a Contracting State which carries on offshore...
4.The provisions of paragraph (3) of this Article shall not...
5.Subject to paragraph (6) of this Article profits derived by...
6.The provisions of paragraph (5) of this Article shall not...
7.A resident of a Contracting State who carries on offshore...
8.Salaries, wages, and other similar remuneration derived by residents of...
9.Gains derived by a resident of a Contracting State from...
Article 27 Non-discrimination/hs
1.Nationals of a Contracting State shall not be subjected in...
2.Stateless persons who are residents of a Contracting State shall...
3.The taxation on a permanent establishment which an enterprise of...
4.Except where the provisions of paragraph (1) of Article 9,...
5.Enterprises of a Contracting State, the capital of which is...
6.Nothing contained in this Article shall be construed as obliging...
7.The provisions of this Article shall apply to the taxes...
Article 30 Members of diplomatic or permanent missions and consular posts