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IN US 1989 CONVENTION

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Contents

ARTICLE 1 · General Scope

ARTICLE 2 · Taxes Covered

ARTICLE 3 · General Definitions

ARTICLE 4 · Residence

ARTICLE 5 · Permanent Establishment

ARTICLE 6 · Income From Immovable Property (Real Property)

ARTICLE 7 · Business Profits

ARTICLE 8 · Shipping and Air Transport

ARTICLE 9 · Associated Enterprises

ARTICLE 10 · Dividends

ARTICLE 11 · Interest

ARTICLE 12 · Royalties and Fees for Included Services

ARTICLE 13 · Gains

ARTICLE 14 · Permanent Establishment Tax

ARTICLE 15 · Independent Personal Services

ARTICLE 16 · Dependent Personal Services

ARTICLE 17 · Directors' Fees

ARTICLE 18 · Income Earned by Entertainers and Athletes

ARTICLE 19 · Remuneration and Pensions in Respect of Government Service

ARTICLE 20 · Private Pensions, Annuities, Alimony and Child Support

ARTICLE 21 · Payments Received by Students and Apprentices

ARTICLE 22 · Payments Received by Professors, Teachers

ARTICLE 23 · Other Income

ARTICLE 24 · Limitation on Benefits

ARTICLE 25 · Relief From Double Taxation

ARTICLE 26 · Non-discrimination

ARTICLE 27 · Mutual Agreement Procedure

ARTICLE 28 · Exchange of Information and Administrative Assistance

ARTICLE 29 · Diplomatic Agents and Consular officers

ARTICLE 30 · Entry Into Force

ARTICLE 31 · Termination