Beruflich Dokumente
Kultur Dokumente
AND
CHAPTER I
SCOPE OF THE AGREEMENT
ARTICLE 1
PERSONS COVERED
ARTICLE 2
TAXES COVERED
CHAPTER II
DEFINITIONS
ARTICLE 3
GENERAL DEFINITIONS
ARTICLE 4
RESIDENT
ARTICLE 5
PERMANENT ESTABLISHMENT
(b) a branch;
(c) an office;
(d) a factory;
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CHAPTER III
TAXATION OF INCOME
ARTICLE 6
INCOME FROM IMMOVABLE PROPERTY
ARTICLE 7
BUSINESS PROFITS
ARTICLE 8
SHIPPING AND AIR TRANSPORT
ARTICLE 9
ASSOCIATED ENTERPRISES
1. Where
and in either case conditions are made or imposed between the two
enterprises in their commercial or financial relations which differ from
those which would be made between independent enterprises, then
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any profits which would, but for those conditions, have accrued to one
of the enterprises, but, by reason of those conditions, have not so
accrued, may be included in the profits of that enterprise and taxed
accordingly.
ARTICLE 10
DIVIDENDS
This paragraph shall not affect the taxation of the company in respect
of the profits out of which the dividends are paid.
ARTICLE 11
INTEREST
ARTICLE 12
ROYALTIES
ARTICLE 13
CAPITAL GAINS
ARTICLE 14
INDEPENDENT PERSONAL SERVICES
ARTICLE 15
DEPENDENT PERSONAL SERVICES
ARTICLE 16
DIRECTORS' FEES
ARTICLE 17
ARTISTES AND SPORTSPERSONS
ARTICLE 18
PENSIONS
ARTICLE 19
GOVERNMENT SERVICE
ARTICLE 20
STUDENTS
ARTICLE 21
OTHER INCOME
CHAPTER IV
METHODS FOR ELIMINATION OF DOUBLE TAXATION
ARTICLE 22
ELIMINATION OF DOUBLE TAXATION
CHAPTER V
SPECIAL PROVISIONS
ARTICLE 23
NON-DISCRIMINATION
ARTICLE 24
MUTUAL AGREEMENT PROCEDURE
ARTICLE 25
EXCHANGE OF INFORMATION
ARTICLE 26
MEMBERS OF DIPLOMATIC MISSIONS AND CONSULAR POSTS
ARTICLE 27
ENTRY INTO FORCE
ARTICLE 28
TERMINATION
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