PROFESSORS, TEACHERS AND RESEARCHERS 1. An individual who is or was immediately before visiting a Contracting State a resident of the other Contracting State, and who, at the invitation of any university, college, school or other similar educational institution which is recognised by the competent authority in the first-mentioned Contracting State, visits that first-mentioned Contracting State for a period not exceeding two years solely for the purpose of teaching or researching or both at such educational institution shall be exempt from tax in the first-mentioned Contracting State on any remuneration for such teaching or research.
2. The provisions of paragraph 1 shall not apply to income from researching if such research is undertaken by the individual primarily for the private benefit of a specific person or persons.
OTHER INCOME Items of income of a resident of a Contracting State not dealt with in the foregoing Articles of this Convention may be taxed in the State where the income arises.
MISCELLANEOUS PROVISIONS 1. Interests, royalties and other fees paid by an enterprise of a Contracting State to a resident of the other Contracting State shall be deducted for the purpose of determination of profits of the enterprise which will be subject to tax in the same conditions as if paid to a resident in the first mentioned State.
2. Where an individual who is a resident for tax purposes of a Contracting State according to the provisions of the domestic laws of this State, is deemed to be a resident for tax purposes of the other Contracting State on the basis of the citizenship criterion provided for under Article 4 paragraph 2 c, the first?mentioned State may refuse to this individual the benefit of tax exemptions or reductions provided for by the Convention to the benefit of residents of the other State, but shall consider nevertheless that individual as a non resident for the purpose of its general laws.
ELIMINATION OF DOUBLE TAXATION
2. Tax payable in a Contracting State in respect of income or profits derived in that State shall be allowed as a credit against any tax payable in the other Contracting State in respect of that income or profits. The credit shall not, however, exceed that part of the tax payable in the other Contracting State as computed before the credit is given, which is appropriate to such item of income or profits.
3. For the purpose of allowance as a credit in a Contracting State the tax paid in the other Contracting State shall be deemed to include the tax which is otherwise payable in that other State but has been reduced or waived in accordance with special incentive laws designed to promote economic development in that other State.
NON - DISCRIMINATION
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.
3. 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.
4. The provisions of this Article shall not be construed as obliging a Contracting State to grant to residents of the other Contracting State any personal allowances, reliefs and reductions for taxation purposes on account of civil status or family responsibilities which it grants to its own residents.
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