This Convention shall apply to persons who are residents of one or both of the Contracting States.

1. This Convention shall apply to taxes on income and on property imposed on behalf  of a Contracting State or of its administrative-territorial units or local authorities, irrespective  of the manner in which they are levied.  

2. There shall be regarded as taxes on income and on property all taxes imposed on  total income, on total property, or on elements of income or of property, including taxes on  gains from the alienation of movable or immovable property, taxes on the total amounts of  wages or salaries paid by enterprises, as well as taxes on capital appreciation.  

3. The existing taxes to which the Convention shall apply are in particular:  

a) in Austria:  

(i) the income tax;  

(ii) the corporation tax;  

(iii) the land tax;  

(iv) the tax on agricultural and forestry enterprises, and  

(v) the tax on the value of vacant plots;  

b) in Moldova:  

(i) the income tax, and  

(ii) the tax on immovable property.  

4. The Convention shall apply also to any identical or substantially similar taxes that  are imposed after the date of signature of the Convention in addition to, or in place of, the  existing taxes. The competent authorities of the Contracting States shall notify each other of  any significant changes that have been made in their taxation laws.

1. For the purposes of this Convention, unless the context otherwise requires:  

a) the terms "a Contracting State" and "the other Contracting State" mean Austria  or Moldova, as the context requires;  

b) the term "Austria" means the Republic of Austria;  

c) the term "Moldova" means the Republic of Moldova and, when used in a  geographical sense, means its territory within its borders, consisting of soil,  subsoil, waters and aerial space above soil and waters, over which the  Republic of Moldova exercises its absolute and exclusive sovereignty and  jurisdiction, in accordance with its internal legislation and international law;  

d) the term "person" includes an individual, a company and any other body of  persons;  

e) the term "company" means any body corporate or any entity that is treated as  a body corporate for tax purposes;  

f) the term "enterprise" applies to the carrying on of any business;  

g) the terms "enterprise of a Contracting State" and "enterprise of the other  Contracting State" mean respectively an enterprise carried on by a resident of  a Contracting State and an enterprise carried on by a resident of the other  Contracting State;  

h) the term "international traffic" means any transport by a ship or aircraft  operated by an enterprise of a Contracting State, except when the ship or  aircraft is operated solely between places in the other Contracting State;  

i) the term "competent authority" means:  

(i) in Austria: the Federal Minister of Finance or his authorised  

representative;  

(ii) in Moldova: the Minister of Finance or his authorised representative;  

j) the term "national" means:  

(i) any individual possessing the nationality of a Contracting State;  

(ii) any legal person, partnership or association deriving its status as such  

from the laws in force in a Contracting State;  

k) the term "business" includes the performance of professional services and of  other activities of an independent character.  

2. As regards the application of the Convention at any time by a Contracting State, any  term not defined therein shall, unless the context otherwise requires, have the meaning that  it has at that time under the law of that State for the purposes of the taxes to which the  Convention applies, any meaning under the applicable tax laws of that State prevailing over  a meaning given to the term under other laws of that State.

1. For the purposes of this Convention, the term "resident of a Contracting State"  means any person who, under the laws of that State, is liable to tax therein by reason of his  domicile, residence, place of registration, place of management or any other criterion of a  similar nature, and also includes that State and any administrative-territorial unit or local  authority thereof. This term, however, does not include any person who is liable to tax in  that State in respect only of income from sources in that State or property situated therein.  

2. Where by reason of the provisions of paragraph 1 an individual is a resident of both  Contracting States, then his status shall be determined as follows:  

a) he shall be deemed to be a resident only of the State in which he has a  permanent home available to him; if he has a permanent home available to  him in both States, he shall be deemed to be a resident only of the State with  which his personal and economic relations are closer (centre of vital interests);  

b) if the State in which he has his centre of vital interests cannot be determined,  or if he has not a permanent home available to him in either State, he shall be  deemed to be a resident only of the State in which he has an habitual abode;  

c) if he has an habitual abode in both States or in neither of them, he shall be  deemed to be a resident only of the State of which he is a national;  

d) if he is a national of both States or of neither of them, the competent authorities  of the Contracting States shall endeavour to settle the question by mutual  agreement.  

3. Where by reason of the provisions of paragraph 1 a person other than an individual  is a resident of both Contracting States, then it shall be deemed to be a resident only of the  State in which its place of effective management is situated.

1. For the purposes of this Convention, the term "permanent establishment" means a  fixed place of business through which the business of an enterprise is wholly or partly  carried on.  

2. The term "permanent establishment" includes especially:  

a) a place of management;  

b) a branch;  

c) an office;  

d) a factory; 

e) a workshop, and  

f) a mine, an oil or gas well, a quarry or any other place of extraction of natural  resources.

3. A building site or construction, assembly or installation project constitutes a  permanent establishment only if it lasts more than twelve months.

4. Notwithstanding the preceding provisions of this Article, the term "permanent  establishment" shall be deemed not to include:  

a) the use of facilities solely for the purpose of storage, display or delivery of goods or  merchandise belonging to the enterprise;  

b) the maintenance of a stock of goods or merchandise belonging to the enterprise  solely for the purpose of storage, display or delivery;  

c) the maintenance of a stock of goods or merchandise belonging to the enterprise  solely for the purpose of processing by another enterprise;  

d) the maintenance of a fixed place of business solely for the purpose of purchasing  goods or merchandise or of collecting information, for the enterprise;  

e) the maintenance of a fixed place of business solely for the purpose of carrying on,  for the enterprise, any other activity of a preparatory or auxiliary character;  

f) the maintenance of a fixed place of business solely for any combination of activities  mentioned in sub-paragraphs a) to e), provided that the overall activity of the fixed  place of business resulting from this combination is of a preparatory or auxiliary  character.

5. Notwithstanding the provisions of paragraphs 1 and 2, where a person - other than  an agent of an independent status to whom the provisions of paragraph 6 apply - is acting  on behalf of an enterprise and has, and habitually exercises, in a Contracting State an  authority to conclude contracts in the name of the enterprise, that enterprise shall be  deemed to have a permanent establishment in that State in respect of any activities which  that person undertakes for the enterprise, unless the activities of such person are limited to  those mentioned in paragraph 4 which, if exercised through a fixed place of business, would  not make this fixed place of business a permanent establishment under the provisions of  that paragraph.

6. An enterprise shall not be deemed to have a permanent establishment in a  Contracting State merely because it carries on business in that State through a broker,  general commission agent or any other agent of an independent status, provided that such  persons are acting in the ordinary course of their business.  

7. Notwithstanding the preceding provisions of this Article, an insurance enterprise of a  Contracting State shall, except the cases of reinsurance, be considered as having a  permanent establishment in the other Contracting State if it collects insurance premiums on  the territory of that other State or insures risks situated therein through a person which is  not an agent of an independent status.

8. The fact that a company which is a resident of a Contracting State controls or is  controlled by a company which is a resident of the other Contracting State, or which carries  on business in that other State (whether through a permanent establishment or otherwise),  shall not of itself constitute either company a permanent establishment of the other.

1. Income derived by a resident of a Contracting State from immovable property  (including income from agriculture or forestry) situated in the other Contracting State may  be taxed in that other State.  

2. The term "immovable property" shall have the meaning which it has under the law of  the Contracting State in which the property in question is situated. The term shall in any  case include property accessory to immovable property, livestock and equipment used in  agriculture and forestry, rights to which the provisions of general law respecting landed  property apply, usufruct of immovable property and rights to variable or fixed payments as  consideration for the working of, or the right to work, mineral deposits, sources and other  natural resources; ships, boats and aircraft shall not be regarded as immovable property.  

3. The provisions of paragraph 1 shall apply to income derived from the direct use,  letting, or use in any other form of immovable property.  

4. The provisions of paragraphs 1 and 3 shall also apply to the income from immovable  property of an enterprise.

1. The profits of an enterprise of a Contracting State shall be taxable only in that State  unless the enterprise carries on business in the other Contracting State through a  permanent establishment situated therein. If the enterprise carries on business as  aforesaid, the profits of the enterprise may be taxed in the other State but only so much of  them as is attributable to that permanent establishment.  

2. Subject to the provisions of paragraph 3, where an enterprise of a Contracting State  carries on business in the other Contracting State through a permanent establishment  situated therein, there shall in each Contracting State be attributed to that permanent  establishment the profits which it might be expected to make if it were a distinct and  separate enterprise engaged in the same or similar activities under the same or similar  conditions and dealing wholly independently with the enterprise of which it is a permanent  establishment.  

3. In determining the profits of a permanent establishment, there shall be allowed as  deductions expenses which are incurred for the purposes of the permanent establishment,  including executive and general administrative expenses so incurred, whether in the State  in which the permanent establishment is situated or elsewhere. However, no such  deduction shall be allowed in respect of amounts, if any, paid (otherwise than towards reimbursement of actual expenses) by the permanent establishment to the head office of  the enterprise or any of its other offices, by way of royalties, fees or other similar payments  in return for the use of patents or other rights, or by way of commission, for specific services  performed or for management, or, except in the case of a banking enterprise, by way of  interest on moneys lent to the permanent establishment. Likewise, no account shall be  taken, in the determination of the profits of a permanent establishment, for amounts  charged (otherwise than towards reimbursement of actual expenses), by the permanent  establishment to the head office of the enterprise or any of its other offices, by way of  royalties, fees or other similar payments in return for the use of patents or other rights, or by  way of commission for specific services performed or for management, or, except in the  case of a banking enterprise by way of interest on moneys lent to the head office of the  enterprise or any of its other offices.

4. Insofar as it has been customary in a Contracting State to determine the profits to be  attributed to a permanent establishment on the basis of an apportionment of the total profits  of the enterprise to its various parts, nothing in paragraph 2 shall preclude that Contracting  State from determining the profits to be taxed by such an apportionment as may be  customary; the method of apportionment adopted shall, however, be such that the result  shall be in accordance with the principles contained in this Article.  

5. No profits shall be attributed to a permanent establishment by reason of the mere  purchase by that permanent establishment of goods or merchandise for the enterprise.  

6. For the purposes of the preceding paragraphs of this Article, the profits to be  attributed to the permanent establishment shall be determined by the same method year by  year unless there is good and sufficient reason to the contrary.  

7.Where profits include items of income which are dealt with separately in other  Articles of this Convention, then the provisions of those Articles shall not be affected by the  provisions of this Article.  

8. The provisions of this Article shall apply also to profits derived by any partner from  his participation in a partnership and in any other body of persons which is subjected to the  same taxation treatment.

1. Profits derived by a resident of a Contracting State from the operation of ships or  aircraft in international traffic shall be taxable only in that State.  

2. For the purpose of this Article, profits from the operation of ships or aircraft in  international traffic include:  

a) profits from the rental on a bare boat basis of ships or aircraft; and  

b) profits from the use, maintenance or rental of containers (including trailers and related  equipment for the transport of containers) used for the transport of goods or  merchandise, where such rental or such use, maintenance or rental, as the case may be, is incidental to  the operation of ships or aircraft in international traffic.

3. The provisions of paragraph 1 shall also apply to profits from the participation in a  pool, a joint business or an international operating agency.

1. Where  

a) an enterprise of a Contracting State participates directly or indirectly in the  management, control or capital of an enterprise of the other Contracting State,  or  

b) the same persons participate directly or indirectly in the management, control  or capital of an enterprise of a Contracting State and an enterprise of the other  Contracting State,

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 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.

2. Where a Contracting State includes in the profits of an enterprise of that State - and  taxes accordingly - profits on which an enterprise of the other Contracting State has been  charged to tax in that other State and the profits so included are profits which would have  accrued to the enterprise of the first-mentioned State if the conditions made between the  two enterprises had been those which would have been made between independent  enterprises, then that other State shall make an appropriate adjustment to the amount of the  tax charged therein on those profits, where that other State considers the adjustment  justified. In determining such adjustment, due regard shall be had to the other provisions of  this Convention and the competent authorities of the Contracting States shall if necessary  consult each other.

1. Dividends paid by a company which is a resident of a Contracting State to a resident  of the other Contracting State may be taxed in that other State.  

2. However, such dividends may also be taxed in the Contracting State of which the  company paying the dividends is a resident and according to the laws of that State, but if the beneficial owner of the dividends is a resident of the other Contracting State, the tax so  charged shall not exceed:

a) 5 per cent of the gross amount of the dividends if the beneficial owner is a  company (other than a partnership) which holds directly at least 25 per cent of  the capital of the company paying the dividends;  

b) 15 per cent of the gross amount of the dividends in all other cases.

The competent authorities of the Contracting States shall by mutual agreement settle the  mode of application of these limitations.  

This paragraph shall not affect the taxation of the company in respect of the profits out of  which the dividends are paid.

3. The term "dividends" as used in this Article means income from shares, "jouissance"  shares or "jouissance" rights, mining shares, founders' shares or other rights, not being  debt-claims, participating in profits, as well as income from other corporate rights which is  subjected to the same taxation treatment as income from shares by the laws of the State of  which the company making the distribution is a resident.  

4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the  dividends, being a resident of a Contracting State, carries on business in the other  Contracting State of which the company paying the dividends is a resident through a  permanent establishment situated therein and the holding in respect of which the dividends  are paid is effectively connected with such permanent establishment. In such case the  provisions of Article 7 shall apply.  

5. Where a company which is a resident of a Contracting State derives profits or  income from the other Contracting State, that other State may not impose any tax on the  dividends paid by that company, except insofar as such dividends are paid to a resident of  that other State or insofar as the holding in respect of which the dividends are paid is  effectively connected with a permanent establishment situated in that other State, nor  subject the company's undistributed profits to a tax on the company's undistributed profits,  even if the dividends paid or the undistributed profits consist wholly or partly of profits or  income arising in such other State.

1. Interest arising in a Contracting State and paid to a resident of the other Contracting  State may be taxed in that other State.  

2. However, such interest may also be taxed in the Contracting State in which it arises  and according to the laws of that State, but if the beneficial owner of the interest is a resident of the other Contracting State, the tax so charged shall not exceed 5 per cent of the  gross amount of the interest. The competent authorities of the Contracting States shall by  mutual agreement settle the mode of application of this limitation.  

3. Notwithstanding the provisions of paragraph 2, interest mentioned in paragraph 1  shall be taxable only in the Contracting State of which the recipient is a resident, if such  recipient is the beneficial owner of the interest and if such interest is paid to, or the loan in  respect of which the interest is paid, is made, guaranteed or insured by, the Government or  the National Bank of a Contracting State.

4. The term "interest" as used in this Article means income from debt-claims of every  kind, whether or not secured by mortgage and whether or not carrying a right to participate  in the debtor's profits, and in particular, income from government securities and income  from bonds or debentures, including premiums and prizes attaching to such securities,  bonds or debentures. Penalty charges for late payment shall not be regarded as interest for  the purpose of this Article.  

5. The provisions of paragraphs 1, 2 and 3 shall not apply if the beneficial owner of the  interest, being a resident of a Contracting State, carries on business in the other  Contracting State in which the interest arises through a permanent establishment situated  therein and the debt-claim in respect of which the interest is paid is effectively connected  with such permanent establishment. In such case the provisions of Article 7 shall apply.  

6. Interest shall be deemed to arise in a Contracting State when the payer is a resident  of that State. Where, however, the person paying the interest, whether he is a resident of a  Contracting State or not, has in a Contracting State a permanent establishment in  connection with which the indebtedness on which the interest is paid was incurred, and  such interest is borne by such permanent establishment, then such interest shall be  deemed to arise in the State in which the permanent establishment is situated.  

7. Where, by reason of a special relationship between the payer and the beneficial  owner or between both of them and some other person, the amount of the interest, having  regard to the debt-claim for which it is paid, exceeds the amount which would have been  agreed upon by the payer and the beneficial owner in the absence of such relationship, the  provisions of this Article shall apply only to the last-mentioned amount. In such case, the  excess part of the payments shall remain taxable according to the laws of each Contracting  State, due regard being had to the other provisions of this Convention.

1. Royalties arising in a Contracting State and paid to a resident of the other  Contracting State may be taxed in that other State.  

2. However, such royalties may also be taxed in the Contracting State in which they  arise and according to the laws of that State, but if the beneficial owner of the royalties is a  resident of the other Contracting State, the tax so charged shall not exceed 5 per cent of the  gross amount of the royalties. The competent authorities of the Contracting States shall by  mutual agreement settle the mode of application of this limitation.  

3. The term "royalties" as used in this Article means payments of any kind received as  a consideration for the use of, or the right to use, any copyright of literary, artistic or  scientific work including cinematography films, any patent, software, trade mark, design or  model, plan, secret formula or process, or for information concerning industrial, commercial  or scientific experience.  

4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the  royalties, being a resident of a Contracting State, carries on business in the other  Contracting State in which the royalties arise through a permanent establishment situated  therein and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment. In such case the provisions of Article 7 shall  apply.

5. Royalties shall be deemed to arise in a Contracting State when the payer is a  resident of that State. Where, however, the person paying the royalties, whether he is a  resident of a Contracting State or not, has in a Contracting State a permanent  establishment in connection with which the liability to pay the royalties was incurred, and  such royalties are borne by such permanent establishment, then such royalties shall be  deemed to arise in the State in which the permanent establishment is situated.  

6. Where, by reason of a special relationship between the payer and the beneficial  owner or between both of them and some other person, the amount of the royalties, having  regard to the use, right or information for which they are paid, exceeds the amount which  would have been agreed upon by the payer and the beneficial owner in the absence of such  relationship, the provisions of this Article shall apply only to the last-mentioned amount. In  such case, the excess part of the payments shall remain taxable according to the laws of  each Contracting State, due regard being had to the other provisions of this Convention.

1. Gains derived by a resident of a Contracting State from the alienation of immovable  property referred to in Article 6 and situated in the other Contracting State may be taxed in  that other State.  

2. 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, including such gains from the alienation of such a permanent  establishment (alone or with the whole enterprise), may be taxed in that other State.  

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

4. Gains from the alienation of any property other than that referred to in paragraphs 1,  2 and 3, shall be taxable only in the Contracting State of which the alienator is a resident.

1. Subject to the provisions of Articles 15, 17 and 18, salaries, wages and other similar  remuneration derived by a resident of a Contracting State in respect of an employment shall  be taxable only in that State unless the employment is exercised in the other Contracting  State. If the employment is so exercised, such remuneration as is derived therefrom may be  taxed in that other State.

2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of  a Contracting State in respect of an employment exercised in the other Contracting State  shall be taxable only in the first-mentioned State if:  

a) the recipient is present in the other State for a period or periods not exceeding  in the aggregate 183 days in any twelve-month period commencing or ending  in the fiscal year concerned, and  

b) the remuneration is paid by, or on behalf of, an employer who is not a resident  of the other State, and  

c) the remuneration is not borne by a permanent establishment which the  employer has in the other State.  

3. Notwithstanding the preceding provisions of this Article, remuneration derived in  respect of an employment exercised aboard a ship or aircraft operated in international  traffic, may be taxed in the State of which the enterprise operating the ship or aircraft is a  resident.

Directors' fees and other similar payments derived by a resident of a Contracting State in  his capacity as a member of the board of directors of a company which is a resident of the  other Contracting State may be taxed in that other State.

1. Notwithstanding the provisions of Articles 7 and 14, income derived by a resident of  a Contracting State as an entertainer, such as a theatre, motion picture, radio or television  artiste, or a musician, or as a sportsman, from his personal activities as such exercised in  the other Contracting State, may be taxed in that other State.  

2. Where income in respect of personal activities exercised by an entertainer or a  sportsman in his capacity as such accrues not to the entertainer or sportsman himself but to  another person, that income may, notwithstanding the provisions of Articles 7 and 14, be  taxed in the Contracting State in which the activities of the entertainer or sportsman are  exercised.

Subject to the provisions of paragraph 2 of Article 18, pensions and other similar  remuneration paid to a resident of a Contracting State in consideration of past employment  shall be taxable only in that State. 

1.  a) Salaries, wages and other similar remuneration, other than a pension, paid by  a Contracting State or an administrative-territorial unit or a local authority  thereof to an individual in respect of services rendered to that State or unit or  authority shall be taxable only in that State.  

b) However, such salaries, wages and other similar remuneration shall be taxable  only in the other Contracting State if the services are rendered in that State  and the individual is a resident of that State who:  

 (i) is a national of that State; or  

 (ii) did not become a resident of that State solely for the purpose of   rendering the services.  

2. a) Any pension paid by, or out of funds created by, a Contracting State or an  administrative-territorial unit or a local authority thereof to an individual in  respect of services rendered to that State or unit or authority shall be taxable  only in that State.  

b) However, such pension shall be taxable only in the other Contracting State if  the individual is a resident of, and a national of, that State.  

3. The provisions of Articles 14, 15, 16, and 17 shall apply to salaries, wages and other  similar remuneration, and to pensions, in respect of services rendered in connection with a  business carried on by a Contracting State or an administrative-territorial unit or a local  authority thereof.

Payments which a student or business apprentice who is or was immediately before  visiting a Contracting State a resident of the other Contracting State and who is present in  the first-mentioned State solely for the purpose of his education or training receives for the  purpose of his maintenance, education or training shall not be taxed in that first-mentioned  State, provided that such payments arise from sources outside that State.

1. Items of income of a resident of a Contracting State, wherever arising, not dealt with  in the foregoing Articles of this Convention shall be taxable only in that State.  

2. The provisions of paragraph 1 shall not apply to income, other than income from  immovable property as defined in paragraph 2 of Article 6, if the recipient of such income,  being a resident of a Contracting State, carries on business in the other Contracting State  through a permanent establishment situated therein and the right or property in respect of  which the income is paid is effectively connected with such permanent establishment. In  such case the provisions of Article 7 shall apply.

1.Property represented by immovable property referred to in Article 6, owned by a  resident of a Contracting State and situated in the other Contracting State, may be taxed in  that other State.  

2. Property represented by 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 may be taxed in that other State.  

3. Property represented by ships and aircraft operated by an enterprise of a  Contracting State in international traffic, and by movable property pertaining to the operation  of such ships and aircraft, shall be taxable only in that State.  

4. All other elements of property of a resident of a Contracting State shall be taxable  only in that State.

Double taxation shall be eliminated as follows:  

1. In Austria:  

a) Where a resident of Austria derives income or owns property which, in accordance  with the provisions of this Convention, may be taxed in Moldova, Austria shall,  subject to the provisions of sub-paragraphs b) and c), exempt such income or  property from tax.  

b) Where a resident of Austria derives items of income which, in accordance with the  provisions of Articles 10, 11 and 12, may be taxed in Moldova, Austria shall allow  as a deduction from the tax on the income of that resident an amount equal to the tax paid in Moldova. Such deduction shall not, however, exceed that part of the tax,  as computed before the deduction is given, which is attributable to such items of  income derived from Moldova.

c) Where in accordance with any provision of the Convention income derived or  property owned by a resident of Austria is exempt from tax in Austria, Austria may  nevertheless, in calculating the amount of tax on the remaining income or property  of such resident, take into account the exempted income or property.  

d) The provisions of sub-paragraph a) shall not apply to income derived or property  owned by a resident of Austria where Moldova applies the provisions of this  Convention to exempt such income or property from tax or applies the provisions of  paragraph 2 of Article 10, 11 or 12 to such income.

2. In Moldova:  

a) Where a resident of Moldova derives income or owns property which, in accordance  with the provisions of this Convention, may be taxed in Austria, Moldova shall allow: 

(i) as a deduction from the tax on the income of that resident, an amount equal to the  income tax paid in Austria;  

(ii) as a deduction from the tax on the property of that resident, an amount equal to the  tax on property paid in Austria.  

Such deduction in either case shall not, however, exceed that part of the income tax or tax  on property, as computed before the deduction is given, which is attributable, as the case  may be, to the income or the property which may be taxed in Austria. 

b) Where in accordance with any provision of the Convention income derived or property  owned by a resident of Moldova is exempt from tax in Moldova, Moldova may nevertheless,  in calculating the amount of tax on the remaining income or property of such resident, take  into account the exempted income or property.

1. Nationals of a Contracting State shall not be subjected in the other Contracting State  to any taxation or any requirement connected therewith, which is other or more burdensome  than the taxation and connected requirements to which nationals of that other State in the  same circumstances, in particular with respect to residence, are or may be subjected.  

2. Stateless persons who are residents of a Contracting State shall not be subjected in  either Contracting State to any taxation or any requirement connected therewith, which is  other or more burdensome than the taxation and connected requirements to which nationals  of the State concerned in the same circumstances, in particular with respect to residence,  are or may be subjected. 

3. The taxation on a permanent establishment which an enterprise of a Contracting  State has in the other Contracting State shall not be less favourably levied in that other  State than the taxation levied on enterprises of that other State carrying on the same  activities. This provision shall not be construed as obliging a Contracting State to grant to residents of the other Contracting State any personal allowances, reliefs and reductions for  taxation purposes on account of civil status or family responsibilities which it grants to its  own residents. 

4. Except where the provisions of paragraph 1 of Article 9, paragraph 7 of Article 11, or  paragraph 6 of Article 12, apply, interest, royalties 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. Similarly, any  debts of an enterprise of a Contracting State to a resident of the other Contracting State  shall, for the purpose of determining the taxable property of such enterprise, be deductible  under the same conditions as if they had been contracted to a resident of the  first-mentioned State.

5. Enterprises of a Contracting State, the capital of which is wholly or partly owned or  controlled, directly or indirectly, by one or more residents of the other Contracting State,  shall not be subjected in the first-mentioned State to any taxation or any requirement  connected therewith which is other or more burdensome than the taxation and connected  requirements to which other similar enterprises of the first-mentioned State are or may be  subjected.

1. Where a person considers that the actions of one or both of the Contracting States  result or will result for him in taxation not in accordance with the provisions of this  Convention, he may, irrespective of the remedies provided by the domestic law of those  States, present his case to the competent authority of the Contracting State of which he is a  resident or, if his case comes under paragraph 1 of Article 23, to that of the Contracting  State of which he is a national. The case must be presented within three years from the first  notification of the action resulting in taxation not in accordance with the provisions of the  Convention.  

2. The competent authority shall endeavour, if the objection appears to it to be justified  and if it is not itself able to arrive at a satisfactory solution, to resolve the case by mutual  agreement with the competent authority of the other Contracting State, with a view to the  avoidance of taxation which is not in accordance with the Convention. Any agreement  reached shall be implemented notwithstanding any time limits in the domestic law of the  Contracting States.  

3. The competent authorities of the Contracting States shall endeavour to resolve by  mutual agreement any difficulties or doubts arising as to the interpretation or application of  the Convention. They may also consult together for the elimination of double taxation in  cases not provided for in the Convention.  

4. The competent authorities of the Contracting States may communicate with each  other directly, including through a joint commission consisting of themselves or their  representatives, for the purpose of reaching an agreement in the sense of the preceding  paragraphs.

1. The competent authorities of the Contracting States shall exchange such information  as is necessary for carrying out the provisions of this Convention. The exchange of  information is not restricted by Article 1. 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, or the determination of appeals in relation to, the taxes covered  by this Convention. Such persons or authorities shall use the information only for such  purposes. They may disclose the information in public court proceedings or in judicial  decisions. Even in such cases the confidentiality of person-related data may be waived only  insofar as this is necessary to safeguard predominant and legitimate interests of another  person or predominant public interests.

2. In no case shall the provisions of paragraph 1 be construed so as to impose on a  Contracting State the obligation:  

a) to carry out administrative measures at variance with the laws and  administrative practice of that or of the other Contracting State;  

b) to supply information which is not obtainable under the laws or in the normal  course of the administration of that or of the other Contracting State;  

c) to supply information which would disclose any trade, business, industrial,  commercial or professional secret or trade process, or information, the  disclosure of which would be contrary to public policy (ordre public) or to the  fundamental rights granted by a State, in particular in the area of data  protection.

Nothing in this Convention shall affect the fiscal privileges of members of diplomatic  missions or consular posts under the general rules of international law or under the  provisions of special agreements.

1. Each of the Contracting States shall notify the other, through diplomatic channels, of  the completion of the procedures required by its law for the entry into force of this  Convention.

2. This Convention shall enter into force sixty days after the date of the latter of the  notifications and its provisions shall have effect:  

a) in respect of taxes withheld at source, on income derived on or after 1st January of the  calendar year next following the year in which the Convention enters into force; 

b) in respect of other taxes on income and on property, for any taxable year beginning on  or after 1st January of the calendar year next following the year in which the  Convention enters into force. 

This Convention shall remain in force until terminated by one of the Contracting States.  Either Contracting State may terminate the Convention, through diplomatic channels, by  giving notice of termination at least six months before the end of any calendar year following  after the period of five years from the date on which the Convention entered into force. In  such event, the Convention shall cease to have effect:  

a) in respect of taxes withheld at source, on income derived on or after 1st January of the  calendar year next following the year in which the notice of termination is given;  

b) in respect of other taxes on income and on property, for any taxable year beginning on  or after 1st January of the calendar year next following the year in which the notice of  termination is given.