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- Nothing in this Convention shall affect the fiscal privileges of members of diplomatic or permanent missions or consular posts under the general rules of international law or under the provisions of special agreements.
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- Notwithstanding the provisions of paragraph 1 of Article 4 of this Convention, an individual who is a member of a diplomatic or permanent mission or consular post of a Contracting State or of any third State which is situated in the other Contracting State or who is an official of an international organisation, and any member of the family of such an individual, shall not be deemed to be a resident of the other State for the purposes of this Convention if the individual is subject to tax on income or capital gains in that other State only if the individual derives income or capital gains from sources therein.
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The following paragraph 1 of Article 7 of the MLI replaces paragraph 6 of Article 10, paragraph 5 of Article 11 and paragraph 5 of Article 12 of this Conventions and applies and supersedes all other provisions of this Convention:
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ARTICLE 7 OF THE MLI – PREVENTION OF TREATY ABUSE (Principal Purposes Test provision)
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Notwithstanding any provisions of [the Convention], a benefit under [the Convention] shall not be granted in respect of an item of income if it is reasonable to conclude, having regard to all relevant facts and circumstances, that obtaining that benefit was one of the principal purposes of any arrangement or transaction that resulted directly or indirectly in that benefit, unless it is established that granting that benefit in these circumstances would be in accordance with the object and purpose of the relevant provisions of [the Convention].