Article 21
STUDENTS

1.             An individual who is or was immediately before visiting a Contracting State a resident of the other Contracting State and whose visit to the first-mentioned Contracting State is solely for the purpose of:

                a)           studying at a university or other recognised educational
                               institution; or

                b)           securing training to qualify him to practice a profession or
                               trade; or

                c)           studying or carrying out research as a recipient of a grant,
                               allowance or award from a governmental, religious, charitable,
                               scientific, literary or educational organisation;

                shall be exempt from tax in the first-mentioned Contracting State on:

                (i)           remittances from abroad for the purposes of his maintenance,
                               education, study, research or training;

                (ii)           the grant, allowance or award from a governmental, religious,
                               charitable, scientific, literary or educational organisation.            

2.             In respect of grants, scholarships and remuneration from employment not covered by paragraph 1 of this Article, a student or business apprentice shall be entitled during such education or training to the same exemptions, reliefs or reductions in respect of taxes as are available to the residents of the Contracting State he is visiting.            

Article 22
OTHER INCOME

1.             Items of income of a resident of a Contracting State, wherever arising, not dealt with in the foregoing Articles of this Convention shall be taxable only in that State.            

2.             The provisions of paragraph 1 shall not apply to income, other than income from immovable property as defined in paragraph 2 of Article 6, if the recipient of such income, being a resident of a Contracting State, carries on business in the other Contracting State through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the income is paid is effectively connected with such permanent establishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply.            

Article 23
ELIMINATION OF DOUBLE TAXATION

1.             Double taxation shall be eliminated as follows:

                a)           Where a resident of a Contracting State derives income which,
                               in accordance with the provisions of this Convention, may be
                               taxed in the other Contracting State, the first-mentioned State
                               shall allow as a deduction from the tax on the income of that
                               resident, an amount equal to the income tax paid in the other State.            

                Such deduction in either case shall not, however, exceed that portion of the income tax, as computed before the deduction is given, which is attributable, as the case may be, to the income which may be taxed in that other State.            

                b)           Where in accordance with any provision of the Convention
                               income derived or by a resident of a Contracting State is
                               exempt from tax in that State, such State may nevertheless,
                               in calculating the amount of tax on the remaining income of
                               such resident, take into account the exempted income.            

2.             For the purpose of subparagraph a) of paragraph 1, the term “tax paid in the other Contracting State” shall be deemed to include any amount which would have been payable in that Contracting State but has been reduced or waived in accordance with special incentive laws designed to promote economic development in such State effective at the date of signature of this Convention.The provisions of this paragraph shall only apply for a period of 10 years beginning on the first day of January of the taxable year n ext following that in which the Convention enters into force. This period may be extended by mutual agreement between the competent authorities.            

Article 24
NON?DISCRIMINATION

1.             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.             This provision shall, notwithstanding the provisions of Article 1, also apply to persons who are not residents of one or both of the Contracting States.            

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.This provision 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.            

3.             Except where the provisions of paragraph 1 of Article 9, paragraph 6 of Article 11, or paragraph 6 of Article 12, apply, interest, royalties and other disbursements paid by an enterprise of a Contracting State to a resident of the other Contracting State shall, for the purpose of determining the taxable profits of such enterprise, be deductible under the same conditions as if they had been paid to a resident of the first?mentioned State.            

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.            

5.             The provisions of this Article shall apply only to taxes covered by this Convention.            

Article 25
MUTUAL AGREEMENT PROCEDURE

1.             Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Convention, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 24, to that of the Con?tracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Convention.            

2.             The competent authority shall endeavour, if the objection appears to it to be justified and if it is not itself able to arrive at a satisfactory solution, to resolve the case by mutual agreement with the competent authority of the other Contracting State, with a view to the avoidance of taxation which is not in accordance with the Convention.            

3.             The competent authorities of the Contracting States shall endeavour to resolve by mutual agreement any difficulties or doubts arising as to the interpretation or application of the Convention. They may also consult together for the elimination of double taxation in cases not provided for in the Convention.            

4.             The competent authorities of the Contracting States may communicate with each other directly for the purpose of reaching an agreement in the sense of the preceding paragraphs.