ARTICLE 1
General Scope
1. This Convention shall apply to persons who are residents
of one or both of the Contracting States, except as otherwise
provided in the Convention.
2. The Convention shall not restrict in any manner any
exclusion, exemption, deduction, credit, or other allowance now
or hereafter accorded:
a) by the laws of either Contracting state; or
b) by any other agreement between the Contracting
States.
3. Notwithstanding any provision of the Convention except
paragraph 4, a Contracting State may tax its residents (as
determined under Article 4 (Residence) ), and by reason of
citizenship may tax its citizens, as if the Convention had not
come into effect. For this purpose, the term "citizen" shall
include a former citizen whose loss of citizenship had as one of
its principal purposes the avoidance of tax, but only for a
period of 10 years following such loss.
4. The provisions of paragraph 3 shall not affect
a) the benefits conferred by a Contracting state under
paragraph 2 of Article 9 (Associated Enterprises), under
paragraphs 2 and 6 of Article 20 (Private Pensions,
Annuities, Alimony, and Child Support), and under Articles 25
(Relief From Double Taxation), 26 (Non-Discrimination), and
27 (Mutual Agreement Procedure); and
b) the benefits conferred by a Contracting state under
Articles 19 (Remuneration and Pensions in Respect of
Government Service), 21 (Payments Received by Students and
Apprentices), 22 (Payments Received by Professors, Teachers
and Research Scholars) and 29 (Diplomatic Agents and Consular
Officers), upon individuals who are neither citizens of, nor
have immigrant status in, that state.