DIPLOMATIC AGENTS AND CONSULAR OFFICERS. 1. Nothing in this Convention shall affect the fiscal privileges of diplomatic agents and consular officers under the general rules of international law or under the provisions of special agreements. 2. Notwithstanding the provisions of Article 4 (Resident), an individual who is a member of a diplomatic mission, consular post or permanent mission of a Contracting State which is situated in the other Contracting State or in a third State shall be deemed, for the purposes of this Convention, to be a resident of the sending State if: a) in accordance with international law he is not liable to tax in the receiving Contracting State in respect of income from sources outside that State and b) he is liable in the sending State to the same obligations in relation to tax on his total income as are residents of that State. 3. The Convention shall not apply to international organisations, to organs or officials thereof and to persons who are members of a diplomatic mission, consular post or permanent mission of a third State, being present in a Contracting State and not treated in either Contracting State as residents in respect of taxes on income.
Appears in 3 contracts
Samples: Double Taxation Avoidance Agreement, Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
DIPLOMATIC AGENTS AND CONSULAR OFFICERS. 1. Nothing in this Convention Connection shall affect the fiscal privileges of diplomatic agents and or consular officers under the general rules of international law or under the provisions of special agreements.
2. Notwithstanding the provisions of Article 4 (Resident)4, an individual who is a member of a diplomatic mission, consular post or permanent mission of a Contracting State which is situated in the other Contracting State or in a third State shall be deemed, for the purposes of this Convention, to be a resident of the sending State if:
a) in accordance with international law he is not liable to tax in in, the receiving Contracting State in respect of income from sources outside outside, that State State, and
b) he is liable in the sending State to the same obligations in relation to tax on his total income as are residents of that State.
3. The Convention shall not apply to international organisations, to organs or officials thereof and to persons who are members of a diplomatic mission, consular post or permanent mission of a third State, being present in a Contracting State and not treated in either Contracting State as residents in respect of taxes on income.
Appears in 2 contracts
Samples: Double Taxation Avoidance Agreement, Convention for the Avoidance of Double Taxation
DIPLOMATIC AGENTS AND CONSULAR OFFICERS. 1. Nothing in this Convention shall affect the fiscal privileges of diplomatic agents and or consular officers under the general rules of international law or under the provisions of special agreements.
2. Notwithstanding the provisions of Article 4 (Resident)4, an individual who is a member of a diplomatic mission, consular post or permanent mission of a Contracting State which is situated in the other Contracting State or in a third State shall be deemed, for the purposes of this Convention, to be a resident of the sending State if:
(a) in accordance with international law he is not liable to tax in the receiving Contracting State in respect of income from sources outside that State or on capital situated outside that State, and
(b) he is liable in the sending State to the same obligations in relation to tax on his total income or on capital as are residents of that State.
3. The Convention shall not apply to international organisations, to organs or officials thereof and to persons who are members of a diplomatic mission, consular post or permanent mission of a third State, being present in a Contracting State and not treated in either Contracting State as residents in respect of taxes on incomeincome or on capital.
Appears in 1 contract
Samples: Double Taxation Convention
DIPLOMATIC AGENTS AND CONSULAR OFFICERS. 1. Nothing in this Convention shall affect the fiscal privileges of diplomatic agents and or consular officers under the general rules of international law or under the provisions of special agreements.
2. Notwithstanding the provisions of Article 4 (Resident)4, an individual who is a member of a diplomatic mission, consular post or permanent mission of a Contracting State which is situated in the other Contracting State or in a third State shall be deemed, for the purposes of this Convention, to be a resident of the sending State if:
a) in accordance with international law he is not liable to tax in the receiving Contracting State in respect of income from sources outside that State or on capital situated outside that State and
b) he is liable in the sending State to the same obligations in relation to tax on his total income or on capital as are residents of that State.
3. The Convention shall not apply to international organisations, to organs or officials thereof and to persons who are members of a diplomatic mission, consular post or permanent mission of a third State, being present in a Contracting State and not treated in either Contracting State as residents in respect of taxes on incomeincome or on capital.
Appears in 1 contract
DIPLOMATIC AGENTS AND CONSULAR OFFICERS. 1. Nothing in this Convention shall affect the fiscal privileges of diplomatic agents and or consular officers under the general rules of international law or under the provisions of special agreements.
2. Notwithstanding the provisions of Article 4 (Resident)4, an individual who is a member of a diplomatic mission, consular post or permanent mission of a Contracting State which is situated in the other Contracting State or in a third State shall be deemed, for the purposes of this Convention, to be a resident of the sending State if:
a) in accordance with international law he is not liable to tax in the receiving Contracting State in respect of income from sources outside that State and
b) he is liable in the sending State to the same obligations in relation to tax on his total income as are residents of that State.
3. The Convention shall not apply to international organisations, to organs or officials thereof and to persons who are members of a diplomatic mission, consular post or permanent mission of a third State, being present in a Contracting State and who are not treated liable in either Contracting State to the same obligations in relation to tax on their total income as are residents in respect of taxes on incomethereof.
Appears in 1 contract
Samples: Income Tax Convention