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- 1. Individuals who are 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.
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- 2. 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.
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- 3. Except where the provisions of paragraph 1 of Article 10, paragraph 4 or 5 of Article 12, paragraph 4 or 5 of Article 13, or paragraph 3 or 4 of Article 23 apply, interest, royalties and other disbursements paid by an enterprise of a Contracting State to a resident of the other Contracting State shall be deductible, for the purpose of determining the taxable profits of that enterprise, under the same conditions as if they had been paid to a resident of the first-mentioned State.
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- 4. 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.
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- 5. Nothing contained in this Article shall be construed as obliging either Contracting State to grant to individuals not resident in that State any of the personal allowances, reliefs and reductions for tax purposes which are granted to individuals so resident.
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- 6. Where an individual exercises an employment in a Contracting State and makes contributions to a pension scheme established in and recognised for tax purposes in the other Contracting State, such contributions shall, in the first-mentioned State, be deductible in determining that individual’s taxable income and shall be treated in that State in the same way and subject to the same conditions and limitations as contributions made to a pension scheme that is recognised for tax purposes in that State, provided that:
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- (a) the individual was not a resident of that State, and was contributing to the pension scheme, or to another pension scheme for which it has been substituted, immediately before he began to exercise employment in that State; and
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- (b) the pension scheme is accepted by the competent authority of that State as generally corresponding to a pension scheme recognised as such for tax purposes by that State.
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- 7. Where the enterprise paying the remuneration of an individual described in paragraph 6 makes contributions to a pension scheme described in that paragraph, such contributions shall not be treated as the taxable income of that individual and shall be allowed as a deduction in computing the profits of the enterprise.
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- 8. For the purposes of paragraph 6:
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- (a) the term ‘a pension scheme’ means an arrangement in which the individual participates in order to secure retirement benefits payable in respect of the employment; and
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- (b) a pension scheme is recognised for tax purposes in a State if the contributions to the scheme would qualify for tax relief in that State.