Article 1
Personal Scope
This Agreement shall apply to persons who are residents of one or both of the Contracting States.
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June 26, 2026
Contents
Article 1 - Personal Scope
Article 2 - Taxes Covered
Article 3 - General Definitions
Article 4 - Resident
Article 5 - Permanent Establishment
Article 6 - Income from Immovable Property
Article 7 - Business Profits
Article 8 - International Traffic
Article 9 - Associated Enterprises
Article 10 - Dividends
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 Athletes
Article 18 - Pensions and Annuities
Article 19 - Government Service
Article 20 - Teachers and Researchers
Article 21 - Students and Trainees
Article 22 - Other Income
Article 23 - Capital
Article 24 - Elimination of Double Taxation
Article 25 - Non-Discrimination
Article 26 - Mutual Agreement Procedure
Article 27 - Exchange of Information
Article 28 - Miscellaneous Rules
Article 29 - Diplomatic and Consular Privileges
Article 30 - Entry into Force
Article 31 - Termination
This Agreement shall apply to persons who are residents of one or both of the Contracting States.