UNITED STATES MODEL

INCOME TAX CONVENTION OF

SEPTEMBER 20, 1996

CONVENTION BETWEEN

THE UNITED STATES OF AMERICA

AND ------- 

FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE 

PREVENTION OF FISCAL EVASION 

WITH RESPECT TO TAXES ON INCOME

The United States of America and -----, desiring to conclude

a Convention for the avoidance of double taxation and the

prevention of fiscal evasion with respect to taxes on income,

have agreed as follows:
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Article 1

GENERAL SCOPE

1. This Convention shall apply only 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

benefit now or hereafter accorded:

a) by the laws of either Contracting State; or

b) by any other agreement between the Contracting

States. 

3. Notwithstanding the provisions of subparagraph 2(b):

(a) the provisions of Article 25(Mutual Agreement

Procedure) of this Convention exclusively shall apply to any

dispute concerning whether a measure is within the scope of

this Convention, and the procedures under this Convention

exclusively shall apply to that dispute; and

(b) unless the competent authorities determine that a

taxation measure is not within the scope of this Convention,

the nondiscrimination obligations of this Convention exclusively shall apply with respect to that measure, except for

such national treatment or most-favored-nation obligations

as may apply to trade in goods under the General Agreement

on Tariffs and Trade. No national treatment or most-favored-nation obligation under any other agreement shall

apply with respect to that measure. 

(c) For the purpose of this paragraph, a "measure" is

a law, regulation, rule, procedure, decision, administrative

action, or any similar provision or action.

4. Notwithstanding any provision of the Convention except

paragraph 5 of this Article, 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 or long-term resident whose loss

of such status had as one of its principal purposes the avoidance
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of tax (as defined under the laws of the Contracting State of

which the person was a citizen or long-term resident), but only

for a period of 10 years following such loss.

5. The provisions of paragraph 4 shall not affect:

a) the benefits conferred by a Contracting State under

paragraph 2 of Article 9 (Associated Enterprises), paragraphs 2 and 5 of Article 18 (Pensions, Social Security,

Annuities, Alimony, and Child Support), and Articles 23

(Relief From Double Taxation), 24 (Non-Discrimination), and

25 (Mutual Agreement Procedure); and

b) the benefits conferred by a Contracting State under

paragraph 6 of Article 18 (Pensions, Social Security,

Annuities, Alimony, and Child Support), Articles 19

(Government Service), 20 (Students and Trainees), and 27

(Diplomatic Agents and Consular Officers), upon individuals

who are neither citizens of, nor have been admitted for

permanent residence in, that State.
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Article 2

TAXES COVERED

1. The existing taxes to which this Convention shall apply

are:

a) in the United States: the Federal income taxes

imposed by the Internal Revenue Code (but excluding social

security taxes), and the Federal excise taxes imposed with

respect to private foundations.

b) in __________ : ________________________________

____________________________________________________________

____________________.

2. The Convention shall apply also to any identical or

substantially similar taxes that are imposed after the date of

signature of the Convention in addition to, or in place of, the

existing taxes. The competent authorities of the Contracting

States shall notify each other of any significant changes that

have been made in their respective taxation laws or other laws

affecting their obligations under the Convention, and of any

official published material concerning the application of the

Convention, including explanations, regulations, rulings, or

judicial decisions.
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Article 3

GENERAL DEFINITIONS

1. For the purposes of this Convention, unless the context

otherwise requires:

a) the term "person" includes an individual, an estate,

a trust, a partnership, a company, and any other body of

persons;

b) the term "company" means any body corporate or any

entity that is treated as a body corporate for tax purposes

according to the laws of the state in which it is organized;

c) the terms "enterprise of a Contracting State" and

"enterprise of the other Contracting State" mean respectively an enterprise carried on by a resident of a Contracting

State, and an enterprise carried on by a resident of the

other Contracting State; the terms also include an

enterprise carried on by a resident of a Contracting State

through an entity that is treated as fiscally transparent in

that Contracting State; 

d) the term "international traffic" means any transport

by a ship or aircraft, except when such transport is solely

between places in a Contracting State;

e) the term "competent authority" means:

(i) in the United States: the Secretary of the

Treasury or his delegate; and

(ii) in ___________: ___________________; 

f) the term "United States" means the United States

of America, and includes the states thereof and the District

of Columbia; such term also includes the territorial sea

thereof and the sea bed and subsoil of the submarine areas

adjacent to that territorial sea, over which the United

States exercises sovereign rights in accordance with

international law; the term, however, does not include

Puerto Rico, the Virgin Islands, Guam or any other United

States possession or territory; 
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g) the term _________ means _________________;

h) the term "national" of a Contracting State, means:

(i) any individual possessing the nationality or

citizenship of that State; and

(ii) any legal person, partnership or association

deriving its status as such from the laws in force in

that State;

i) the term "qualified governmental entity" means:

(i) any person or body of persons that constitutes

a governing body of a Contracting State, or of a political subdivision or local authority of a Contracting

State;

(ii) a person that is wholly owned, directly or

indirectly, by a Contracting State or a political

subdivision or local authority of a Contracting State,

provided (A) it is organized under the laws of the

Contracting State, (B) its earnings are credited to its

own account with no portion of its income inuring to

the benefit of any private person, and (C) its assets

vest in the Contracting State, political subdivision or

local authority upon dissolution; and

(iii) a pension trust or fund of a person described in subparagraph (i) or (ii) that is constituted

and operated exclusively to administer or provide

pension benefits described in Article 19;

provided that an entity described in subparagraph (ii) or

(iii) does not carry on commercial activities.

2. As regards the application of the Convention at any

time by a Contracting State any term not defined therein shall,

unless the context otherwise requires, or the competent authorities agree to a common meaning pursuant to the provisions of

Article 25 (Mutual Agreement Procedure), have the meaning which

it has at that time under the law of that State for the purposes

of the taxes to which the Convention applies, any meaning under

the applicable tax laws of that State prevailing over a meaning

given to the term under other laws of that State.
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Article 4

RESIDENCE

1. Except as provided in this paragraph, for the purposes

of this Convention, the term "resident of a Contracting State"

means any person who, under the laws of that State, is liable to

tax therein by reason of his domicile, residence, citizenship,

place of management, place of incorporation, or any other

criterion of a similar nature.

a) The term “resident of a Contracting State” does not

include any person who is liable to tax in that State in

respect only of income from sources in that State or of

profits attributable to a permanent establishment in that

State. 

b) A legal person organized under the laws of a

Contracting State and that is generally exempt from tax in

that State and is established and maintained in that State

either:

i) exclusively for a religious, charitable,

educational, scientific, or other similar purpose; or

ii) to provide pensions or other similar benefits

to employees pursuant to a plan

is to be treated for purposes of this paragraph as a resident of that Contracting State.

c) A qualified governmental entity is to be treated as

a resident of the Contracting State where it is established. 

d) An item of income, profit or gain derived through

an entity that is fiscally transparent under the laws of

either Contracting State shall be considered to be derived

by a resident of a State to the extent that the item is

treated for purposes of the taxation law of such Contracting

State as the income, profit or gain of a resident.

2. Where by reason of the provisions of paragraph 1, an

individual is a resident of both Contracting States, then his

status shall be determined as follows:
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a) he shall be deemed to be a resident of the State in

which he has a permanent home available to him; if he has a

permanent home available to him in both States, he shall be

deemed to be a resident of the State with which his personal

and economic relations are closer (center of vital interests);

b) if the State in which he has his center of vital

interests cannot be determined, or if he does not have a

permanent home available to him in either State, he shall be

deemed to be a resident of the State in which he has an

habitual abode;

c) if he has an habitual abode in both States or in

neither of them, he shall be deemed to be a resident of the

State of which he is a national;

d) if he is a national of both States or of neither of

them, the competent authorities of the Contracting States

shall endeavor to settle the question by mutual agreement.

3. Where by reason of the provisions of paragraph 1 a

company is a resident of both Contracting States, then if it is

created under the laws of one of the Contracting States or a

political subdivision thereof, it shall be deemed to be a

resident of that State.

4. Where by reason of the provisions of paragraph 1 a

person other than an individual or a company is a resident of

both Contracting States, the competent authorities of the Contracting States shall endeavor to settle the question by mutual

agreement and determine the mode of application of the Convention

to such person.
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Article 5

PERMANENT ESTABLISHMENT

1. For the purposes of this Convention, the term "permanent

establishment" means a fixed place of business through which the

business of an enterprise is wholly or partly carried on.

2. The term "permanent establishment" includes especially:

a) a place of management;

b) a branch;

c) an office;

d) a factory;

e) a workshop; and

f) a mine, an oil or gas well, a quarry, or any other

place of extraction of natural resources.

3. A building site or construction or installation project,

or an installation or drilling rig or ship used for the exploration of natural resources, constitutes a permanent establishment

only if it lasts or the activity continues for more than twelve

months.

4. Notwithstanding the preceding provisions of this Article, the term "permanent establishment" shall be deemed not to

include:

a) the use of facilities solely for the purpose of

storage, display or delivery of goods or merchandise belonging to the enterprise;

b) the maintenance of a stock of goods or merchandise

belonging to the enterprise solely for the purpose of storage, display or delivery;

c) the maintenance of a stock of goods or merchandise

belonging to the enterprise solely for the purpose of processing by another enterprise;
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d) the maintenance of a fixed place of business solely

for the purpose of purchasing goods or merchandise, or of

collecting information, for the enterprise;

e) the maintenance of a fixed place of business solely

for the purpose of carrying on, for the enterprise, any

other activity of a preparatory or auxiliary character;

f) the maintenance of a fixed place of business solely

for any combination of the activities mentioned in subparagraphs a) through e).

5. Notwithstanding the provisions of paragraphs 1 and 2,

where a person -- other than an agent of an independent status to

whom paragraph 6 applies -- is acting on behalf of an enterprise

and has and habitually exercises in a Contracting State an

authority to conclude contracts that are binding on the

enterprise, that enterprise shall be deemed to have a permanent

establishment in that State in respect of any activities that the

person undertakes for the enterprise, unless the activities of

such person are limited to those mentioned in paragraph 4 that,

if exercised through a fixed place of business, would not make

this fixed place of business a permanent establishment under the

provisions of that paragraph.

6. An enterprise shall not be deemed to have a permanent

establishment in a Contracting State merely because it carries on

business in that State through a broker, general commission

agent, or any other agent of an independent status, provided that

such persons are acting in the ordinary course of their business

as independent agents. 

7. The fact that a company that is a resident of a Contracting State controls or is controlled by a company that is a

resident of the other Contracting State, or that carries on

business in that other State (whether through a permanent establishment or otherwise), shall not constitute either company a

permanent establishment of the other.
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Article 6

INCOME FROM REAL PROPERTY (IMMOVABLE PROPERTY)

1. Income derived by a resident of a Contracting State from

real property (immovable property), including income from agriculture or forestry, situated in the other Contracting State may

be taxed in that other State.

2. The term "real property (immovable property)" shall have

the meaning which it has under the law of the Contracting State

in which the property in question is situated. 

3. The provisions of paragraph 1 shall apply to income

derived from the direct use, letting, or use in any other form of

real property.

4. The provisions of paragraphs 1 and 3 shall also apply to

the income from real property of an enterprise and to income from

real property used for the performance of independent personal

services.

5. A resident of a Contracting State who is liable to tax

in the other Contracting State on income from real property

situated in the other Contracting State may elect for any taxable

year to compute the tax on such income on a net basis as if such

income were business profits attributable to a permanent establishment in such other State. Any such election shall be binding

for the taxable year of the election and all subsequent taxable

years unless the competent authority of the Contracting State in

which the property is situated agrees to terminate the election. 
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Article 7

BUSINESS PROFITS

1. The business profits of an enterprise of a Contracting

State shall be taxable only in that State unless the enterprise

carries on business in the other Contracting State through a

permanent establishment situated therein. If the enterprise

carries on business as aforesaid, the business profits of the

enterprise may be taxed in the other State but only so much of

them as are attributable to that permanent establishment.

2. Subject to the provisions of paragraph 3, where an

enterprise of a Contracting State carries on business in the

other Contracting State through a permanent establishment situated therein, there shall in each Contracting State be attributed

to that permanent establishment the business profits that it

might be expected to make if it were a distinct and independent

enterprise engaged in the same or similar activities under the

same or similar conditions. For this purpose, the business

profits to be attributed to the permanent establishment shall

include only the profits derived from the assets or activities of

the permanent establishment.

3. In determining the business profits of a permanent

establishment, there shall be allowed as deductions expenses that

are incurred for the purposes of the permanent establishment,

including a reasonable allocation of executive and general

administrative expenses, research and development expenses,

interest, and other expenses incurred for the purposes of the

enterprise as a whole (or the part thereof which includes the

permanent establishment), whether incurred in the State in which

the permanent establishment is situated or elsewhere.

4. No business profits shall be attributed to a permanent

establishment by reason of the mere purchase by that permanent

establishment of goods or merchandise for the enterprise.

5. For the purposes of the preceding paragraphs, the

profits to be attributed to the permanent establishment shall be

determined by the same method of accounting year by year unless

there is good and sufficient reason to the contrary. 

6. Where business profits include items of income that are

dealt with separately in other Articles of the Convention, then
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the provisions of those Articles shall not be affected by the

provisions of this Article.

7. For the purposes of the Convention, the term "business

profits" means income from any trade or business, including

income derived by an enterprise from the performance of personal

services, and from the rental of tangible personal property. 

8. In applying paragraphs 1 and 2 of Article 7 (Business

Profits), paragraph 6 of Article 10 (Dividends), paragraph 3 of

Article 11 (Interest), paragraph 3 of Article 12 (Royalties),

paragraph 3 of Article 13 (Gains), Article 14 (Independent

Personal Services) and paragraph 2 of Article 21 (Other Income),

any income or gain attributable to a permanent establishment or

fixed base during its existence is taxable in the Contracting

State where such permanent establishment or fixed base is situated even if the payments are deferred until such permanent establishment or fixed base has ceased to exist. 
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Article 8

SHIPPING AND AIR TRANSPORT

1. Profits of an enterprise of a Contracting State from the

operation of ships or aircraft in international traffic shall be

taxable only in that State. 

2. For the purposes of this Article, profits from the

operation of ships or aircraft include profits derived from the

rental of ships or aircraft on a full (time or voyage) basis. 

They also include profits from the rental of ships or aircraft on

a bareboat basis if such ships or aircraft are operated in

international traffic by the lessee, or if the rental income is

incidental to profits from the operation of ships or aircraft in

international traffic. Profits derived by an enterprise from the

inland transport of property or passengers within either

Contracting State, shall be treated as profits from the operation

of ships or aircraft in international traffic if such transport

is undertaken as part of international traffic. 

3. Profits of an enterprise of a Contracting State from the

use, maintenance, or rental of containers (including trailers,

barges, and related equipment for the transport of containers)

used in international traffic shall be taxable only in that

State.

4. The provisions of paragraphs 1 and 3 shall also apply to

profits from participation in a pool, a joint business, or an

international operating agency.
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Article 9

ASSOCIATED ENTERPRISES

1. Where:

a) an enterprise of a Contracting State participates

directly or indirectly in the management, control or capital

of an enterprise of the other Contracting State; or

b) the same persons participate directly or indirectly

in the management, control, or capital of an enterprise of a

Contracting State and an enterprise of the other Contracting

State,

and in either case conditions are made or imposed between the two

enterprises in their commercial or financial relations that

differ from those that would be made between independent enterprises, then, any profits that, but for those conditions, would

have accrued to one of the enterprises, but by reason of those

conditions have not so accrued, may be included in the profits of

that enterprise and taxed accordingly. 

2. Where a Contracting State includes in the profits of an

enterprise of that State, and taxes accordingly, profits on which

an enterprise of the other Contracting State has been charged to

tax in that other State, and the other Contracting State agrees

that the profits so included are profits that would have accrued

to the enterprise of the first-mentioned State if the conditions

made between the two enterprises had been those that would have

been made between independent enterprises, then that other State

shall make an appropriate adjustment to the amount of the tax

charged therein on those profits. In determining such adjustment, due regard shall be paid to the other provisions of this

Convention and the competent authorities of the Contracting

States shall if necessary consult each other.
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Article 10

DIVIDENDS

1. Dividends paid by a resident of a Contracting State to a

resident of the other Contracting State may be taxed in that

other State.

2. However, such dividends may also be taxed in the Contracting State of which the payor is a resident and according to

the laws of that State, but if the dividends are beneficially

owned by a resident of the other Contracting State, except as

otherwise provided, the tax so charged shall not exceed:

a) 5 percent of the gross amount of the dividends if

the beneficial owner is a company that owns directly at

least 10 percent of the voting stock of the company paying

the dividends;

b) 15 percent of the gross amount of the dividends in

all other cases. 

This paragraph shall not affect the taxation of the company in

respect of the profits out of which the dividends are paid.

3. Subparagraph a) of paragraph 2 shall not apply in the

case of dividends paid by a United States person that is a

Regulated Investment Company or a Real Estate Investment Trust

(REIT). In the case of a United States person that is a REIT,

subparagraph b) of paragraph 2 also shall not apply, unless the

dividend is beneficially owned by an individual holding a less

than 10-percent interest in the REIT.

4. Notwithstanding paragraph 2, dividends may not be taxed

in the Contracting State of which the payor is a resident if the

beneficial owner of the dividends is a resident of the other

Contracting State that is a qualified governmental entity that

does not control the payor of the dividend.

5. For purposes of the Convention, the term "dividends"

means income from shares or other rights, not being debt-claims,

participating in profits, as well as income that is subjected to

the same taxation treatment as income from shares under the laws

of the State of which the payor is a resident. 
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6. The provisions of paragraphs 1 and 2 shall not apply if

the beneficial owner of the dividends, being a resident of a Contracting State, carries on business in the other Contracting

State, of which the payor is a resident, through a permanent

establishment situated therein, or performs in that other State

independent personal services from a fixed base situated therein,

and the dividends are attributable to such permanent

establishment or fixed base. In such case the provisions of

Article 7 (Business Profits) or Article 14 (Independent Personal

Services), as the case may be, shall apply.

7. A Contracting State may not impose any tax on dividends

paid by a resident of the other State, except insofar as the

dividends are paid to a resident of the first-mentioned State or

the dividends are attributable to a permanent establishment or a

fixed base situated in that State, nor may it impose tax on a

corporation's undistributed profits, except as provided in

paragraph 8, even if the dividends paid or the undistributed

profits consist wholly or partly of profits or income arising in

that State.

8. A corporation that is a resident of one of the States

and that has a permanent establishment in the other State or that

is subject to tax in the other State on a net basis on its income

that may be taxed in the other State under Article 6 (Income from

Real Property (Immoveable Property)) or under paragraph 1 of

Article 13 (Gains) may be subject in that other State to a tax in

addition to the tax allowable under the other provisions of this

Convention. Such tax, however, may be imposed on only the

portion of the business profits of the corporation attributable

to the permanent establishment and the portion of the income

referred to in the preceding sentence that is subject to tax

under Article 6 (Income from Real Property (Immoveable Property))

or under paragraph 1 of Article 13 (Gains) that, in the case of

the United States, represents the dividend equivalent amount of

such profits or income and, in the case of __________, is an

amount that is analogous to the dividend equivalent amount.

9. The tax referred to in paragraph 8 may not be imposed at

a rate in excess of the rate specified in paragraph 2 a). 
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Article 11

INTEREST

1. Interest arising in a Contracting State and beneficially

owned by a resident of the other Contracting State may be taxed

only in that other State.

2. The term "interest" as used in this Convention means

income from debt-claims of every kind, whether or not secured by

mortgage, and whether or not carrying a right to participate in

the debtor's profits, and in particular, income from government

securities and income from bonds or debentures, including premiums or prizes attaching to such securities, bonds or debentures,

and all other income that is subjected to the same taxation

treatment as income from money lent by the taxation law of the

Contracting State in which the income arises. Income dealt with

in Article 10 (Dividends) and penalty charges for late payment

shall not be regarded as interest for the purposes of this

Convention.

3. The provisions of paragraph 1 shall not apply if the

beneficial owner of the interest, being a resident of a Contracting State, carries on business in the other Contracting

State, in which the interest arises, through a permanent establishment situated therein, or performs in that other State

independent personal services from a fixed base situated therein,

and the interest is attributable to such permanent establishment

or fixed base. In such case the provisions of Article 7 (Business Profits) or Article 14 (Independent Personal Services), as

the case may be, shall apply.

4. Where, by reason of a special relationship between the

payer and the beneficial owner or between both of them and some

other person, the amount of the interest, having regard to the

debt-claim for which it is paid, exceeds the amount which would

have been agreed upon by the payer and the beneficial owner in

the absence of such relationship, the provisions of this Article

shall apply only to the last-mentioned amount. In such case the

excess part of the payments shall remain taxable according to the

laws of each State, due regard being had to the other provisions

of this Convention.

5. Notwithstanding the provisions of paragraph 1:
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a) interest paid by a resident of a Contracting State

and that is determined with reference to receipts, sales,

income, profits or other cash flow of the debtor or a

related person, to any change in the value of any property

of the debtor or a related person or to any dividend,

partnership distribution or similar payment made by the

debtor to a related person, and paid to a resident of the

other State also may be taxed in the Contracting State in

which it arises, and according to the laws of that State,

but if the beneficial owner is a resident of the other

Contracting State, the gross amount of the interest may be

taxed at a rate not exceeding the rate prescribed in

subparagraph b) of paragraph 2 of Article 10 (Dividends);

and

b) Interest that is an excess inclusion with respect

to a residual interest in a real estate mortgage investment

conduit may be taxed by each State in accordance with its

domestic law.
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Article 12

ROYALTIES

1. Royalties arising in a Contracting State and beneficially owned by a resident of the other Contracting State may be

taxed only in that other State.

2. The term "royalties" as used in this Convention means:

(a) any consideration for the use of, or the right to

use, any copyright of literary, artistic, scientific or

other work (including computer software, cinematographic

films, audio or video tapes or disks, and other means of

image or sound reproduction), any patent, trademark, design

or model, plan, secret formula or process, or other like

right or property, or for information concerning industrial,

commercial, or scientific experience; and 

(b) gain derived from the alienation of any property

described in subparagraph (a), provided that such gain is

contingent on the productivity, use, or disposition of the

property. 

3. The provisions of paragraph 1 shall not apply if the

beneficial owner of the royalties, 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 royalties are attributable

to such permanent establishment or fixed base. In such case the

provisions of Article 7 (Business Profits) or Article 14 (Independent Personal Services), as the case may be, shall apply.

4. Where, by reason of a special relationship between the

payer and the beneficial owner or between both of them and some

other person, the amount of the royalties, having regard to the

use, right, or information for which they are paid, exceeds the

amount which would have been agreed upon by the payer and the

beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned 

amount. In such case the excess part of the payments shall

remain taxable according to the laws of each Contracting State,

due regard being had to the other provisions of the Convention.
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Article 13

GAINS

1. Gains derived by a resident of a Contracting State that

are attributable to the alienation of real property situated in

the other Contracting State may be taxed in that other State.

2. For the purposes of this Convention the term "real

property situated in the other Contracting State" shall include: 

a) real property referred to in Article 6 (Income from

Real Property (Immovable Property)); 

b) a United States real property interest; and

c) an equivalent interest in real property situated in

_____.

3. Gains from the alienation of personal property that are

attributable to a permanent establishment that an enterprise of a

Contracting State has in the other Contracting State, or that are

attributable to a fixed base that is available to a resident of a

Contracting State in the other Contracting State for the purpose

of performing independent personal services, and gains from the

alienation of such a permanent establishment (alone or with the

whole enterprise) or of such a fixed base, may be taxed in that

other State.

4. Gains derived by an enterprise of a Contracting State

from the alienation of ships, aircraft, or containers operated or

used in international traffic or personal property pertaining to

the operation or use of such ships, aircraft, or containers shall

be taxable only in that State. 

5. Gains from the alienation of any property other than

property referred to in paragraphs 1 through 4 shall be taxable

only in the Contracting State of which the alienator is a resident. 
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Article 14

INDEPENDENT PERSONAL SERVICES

1. Income derived by an individual who is a resident of a

Contracting State in respect of the performance of personal

services of an independent character shall be taxable only in

that State, unless the individual has a fixed base regularly

available to him in the other Contracting State for the purpose

of performing his activities. If he has such a fixed base, the

income attributable to the fixed base that is derived in respect

of services performed in that other State also may be taxed by

that other State.

2. For purposes of paragraph 1, the income that is taxable

in the other Contracting State shall be determined under the

principles of paragraph 3 of Article 7.
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Article 15

DEPENDENT PERSONAL SERVICES

1. Subject to the provisions of Articles 16 (Directors'

Fees), 18 (Pensions, Social Security, Annuities, Alimony, and

Child Support) and 19 (Government Service), salaries, wages, and

other remuneration derived by a resident of a Contracting State

in respect of an employment shall be taxable only in that State

unless the employment is exercised in the other Contracting

State. If the employment is so exercised, such remuneration as

is derived therefrom may be taxed in that other State.

2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of

an employment exercised in the other Contracting State shall be

taxable only in the first-mentioned State if:

a) the recipient is present in the other State for a

period or periods not exceeding in the aggregate 183 days in

any twelve month period commencing or ending in the taxable

year concerned;

b) the remuneration is paid by, or on behalf of, an

employer who is not a resident of the other State; and

c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other

State.

3. Notwithstanding the preceding provisions of this Article,

remuneration described in paragraph 1 that is derived by a resident of a Contracting State in respect of an employment as a

member of the regular complement of a ship or aircraft operated

in international traffic shall be taxable only in that State.
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Article 16

DIRECTORS' FEES

Directors' fees and other compensation derived by a resident

of a Contracting State for services rendered in the other Contracting State in his capacity as a member of the board of

directors of a company that is a resident of the other Contracting State may be taxed in that other Contracting State.
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Article 17

ARTISTES AND SPORTSMEN

1. Income derived by a resident of a Contracting State as

an entertainer, such as a theater, motion picture, radio, or

television artiste, or a musician, or as a sportsman, from his

personal activities as such exercised in the other Contracting

State, which income would be exempt from tax in that other

Contracting State under the provisions of Articles 14 (Independent Personal Services) and 15 (Dependent Personal Services) may

be taxed in that other State, except where the amount of the

gross receipts derived by such entertainer or sportsman, including expenses reimbursed to him or borne on his behalf, from such

activities does not exceed twenty thousand United States dollars

($20,000) or its equivalent in ______ for the taxable year

concerned. 

2. Where income in respect of activities exercised by an

entertainer or a sportsman in his capacity as such accrues not to

the entertainer or sportsman himself but to another person, that

income, notwithstanding the provisions of Articles 7 (Business

Profits) and 14 (Independent Personal Services), may be taxed in

the Contracting State in which the activities of the entertainer

or sportsman are exercised, unless it is established that neither

the entertainer or sportsman nor persons related thereto

participate directly or indirectly in the profits of that other

person in any manner, including the receipt of deferred

remuneration, bonuses, fees, dividends, partnership distributions, or other distributions.
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Article 18

PENSIONS, SOCIAL SECURITY, ANNUITIES, 

ALIMONY, AND CHILD SUPPORT

1. Subject to the provisions of Article 19 (Government

Service), pension distributions and other similar remuneration

beneficially owned by a resident of a Contracting State, whether

paid periodically or as a single sum, shall be taxable only in

that State, but only to the extent not included in taxable income

in the other Contracting State prior to the distribution.

2. Notwithstanding the provisions of paragraph 1, payments

made by a Contracting State under provisions of the social

security or similar legislation of that State to a resident of

the other Contracting State or to a citizen of the United States

shall be taxable only in the first-mentioned State.

3. Annuities derived and beneficially owned by an

individual resident of a Contracting State shall be taxable only

in that State. The term "annuities" as used in this paragraph

means a stated sum paid periodically at stated times during a

specified number of years, under an obligation to make the

payments in return for adequate and full consideration (other

than services rendered).

4. Alimony paid by a resident of a Contracting State, and

deductible therein, to a resident of the other Contracting State

shall be taxable only in that other State. The term "alimony" as

used in this paragraph means periodic payments made pursuant to a

written separation agreement or a decree of divorce, separate

maintenance, or compulsory support, which payments are taxable to

the recipient under the laws of the State of which he is a

resident.

5. Periodic payments, not dealt with in paragraph 4, for

the support of a child made pursuant to a written separation

agreement or a decree of divorce, separate maintenance, or

compulsory support, paid by a resident of a Contracting State to

a resident of the other Contracting State, shall be exempt from

tax in both Contracting States.

6. For purposes of this Convention, where an individual who

is a participant in a pension plan that is established and
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recognized under the legislation of one of the Contracting States

performs personal services in the other Contracting State: 

a) Contributions paid by or on behalf of the

individual to the plan during the period that he performs

such services in the other State shall be deductible (or

excludible) in computing his taxable income in that State. 

Any benefits accrued under the plan or payments made to the

plan by or on behalf of his employer during that period

shall not be treated as part of the employee's taxable

income and shall be allowed as a deduction in computing the

profits of his employer in that other State. 

b) Income earned but not distributed by the plan shall

not be taxable in the other State until such time and to the

extent that a distribution is made from the plan.

c) Distributions from the plan to the individual shall

not be subject to taxation in the other Contracting State if

the individual contributes such amounts to a similar plan

established in the other State within a time period and in

accordance with any other requirements imposed under the

laws of the other State.

d) The provisions of this paragraph shall not apply

unless: 

(i) contributions by or on behalf of the

individual to the plan (or to another similar plan for

which this plan was substituted) were made before he

arrived in the other State; and

(ii) the competent authority of the other State

has agreed that the pension plan generally corresponds

to a pension plan recognized for tax purposes by that

State. 

The benefits granted under this paragraph shall not exceed the

benefits that would be allowed by the other State to its

residents for contributions to, or benefits otherwise accrued

under a pension plan recognized for tax purposes by that State.
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Article 19

GOVERNMENT SERVICE

1. Notwithstanding the provisions of Articles 14 (Independent Personal Services), 15 (Dependent Personal Services), 16

(Director's Fees) and 17 (Artistes and Sportsmen): 

a) Salaries, wages and other remuneration, other than

a pension, paid from the public funds of a Contracting State

or a political subdivision or a local authority thereof to

an individual in respect of services rendered to that State

or subdivision or authority in the discharge of functions of

a governmental nature shall, subject to the provisions of

subparagraph (b), be taxable only in that State;

b) such remuneration, however, shall be taxable only

in the other Contracting State if the services are rendered

in that State and the individual is a resident of that State

who:

i) is a national of that State; or

ii) did not become a resident of that State solely

for the purpose of rendering the services.

2. Notwithstanding the provisions of paragraph 1 of

Article 18 (Pensions, Social Security, Annuities, Alimony, and

Child Support): 

a) any pension paid from the public funds of a Contracting State or a political subdivision or a local authority thereof to an individual in respect of services rendered

to that State or subdivision or authority in the discharge

of functions of a governmental nature shall, subject to the

provisions of subparagraph (b), be taxable only in that

State;

b) such pension, however, shall be taxable only in the

other Contracting State if the individual is a resident of,

and a national of, that State.
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Article 20

STUDENTS AND TRAINEES

Payments received by a student, apprentice, or business

trainee who is, or was immediately before visiting a Contracting

State, a resident of the other Contracting State, and who is

present in the first-mentioned State for the purpose of his fulltime education at an accredited educational institution, or for

his full-time training, shall not be taxed in that State, provided that such payments arise outside that State, and are for the

purpose of his maintenance, education or training. The exemption

from tax provided by this Article shall apply to an apprentice or

business trainee only for a period of time not exceeding one year

from the date he first arrives in the first-mentioned Contracting

State for the purpose of his training.
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Article 21

OTHER INCOME

1. Items of income beneficially owned by 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 real property as defined in paragraph 2 of

Article 6 (Income from Real Property (Immovable Property)), if

the beneficial owner of the 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 income is attributable to

such permanent establishment or fixed base. In such case the

provisions of Article 7 (Business Profits) or Article 14 (Independent Personal Services), as the case may be, shall apply.
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Article 22

LIMITATION ON BENEFITS

1. A resident of a Contracting State shall be entitled to

benefits otherwise accorded to residents of a Contracting State

by this Convention only to the extent provided in this Article. 

2. A resident of a Contracting State shall be entitled to

all the benefits of this Convention if the resident is: 

a) an individual;

b) a qualified governmental entity; 

c) a company, if

i) all the shares in the class or classes of

shares representing more than 50 percent of the voting

power and value of the company are regularly traded on

a recognized stock exchange, or

ii) at least 50 percent of each class of shares in

the company is owned directly or indirectly by

companies entitled to benefits under clause i),

provided that in the case of indirect ownership, each

intermediate owner is a person entitled to benefits of

the Convention under this paragraph; 

d) described in subparagraph 1(b)(i) of Article 4

(Residence); 

e) described in subparagraph 1(b)(ii) of Article 4

(Residence), provided that more than 50 percent of the

person's beneficiaries, members or participants are 

individuals resident in either Contracting State; or

f) a person other than an individual, if:

i) On at least half the days of the taxable year

persons described in subparagraphs a), b), c), d) or e)

own, directly or indirectly (through a chain of

ownership in which each person is entitled to benefits

of the Convention under this paragraph), at least 50

percent of each class of shares or other beneficial

interests in the person, and
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ii) less than 50 percent of the person's gross

income for the taxable year is paid or accrued,

directly or indirectly, to persons who are not

residents of either Contracting State (unless the

payment is attributable to a permanent establishment

situated in either State), in the form of payments that

are deductible for income tax purposes in the person’s

State of residence.

3. a) A resident of a Contracting State not otherwise

entitled to benefits shall be entitled to the benefits of

this Convention with respect to an item of income derived

from the other State, if:

i) the resident is engaged in the active conduct

of a trade or business in the first-mentioned State,

ii) the income is connected with or incidental to

the trade or business, and 

iii) the trade or business is substantial in

relation to the activity in the other State generating

the income.

b) For purposes of this paragraph, the business of

making or managing investments will not be considered an

active trade or business unless the activity is banking,

insurance or securities activity conducted by a bank,

insurance company or registered securities dealer.

c) Whether a trade or business is substantial for

purposes of this paragraph will be determined based on all

the facts and circumstances. In any case, however, a trade

or business will be deemed substantial if, for the preceding

taxable year, or for the average of the three preceding

taxable years, the asset value, the gross income, and the

payroll expense that are related to the trade or business in

the first-mentioned State equal at least 7.5 percent of the

resident's (and any related parties') proportionate share of

the asset value, gross income and payroll expense,

respectively, that are related to the activity that

generated the income in the other State, and the average of

the three ratios exceeds 10 percent.

d) Income is derived in connection with a trade or

business if the activity in the other State generating the
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income is a line of business that forms a part of or is

complementary to the trade or business. Income is

incidental to a trade or business if it facilitates the

conduct of the trade or business in the other State.

4. A resident of a Contracting State not otherwise entitled

to benefits may be granted benefits of the Convention if the

competent authority of the State from which benefits are claimed

so determines. 

5. For purposes of this Article the term "recognized stock

exchange" means:

a) the NASDAQ System owned by the National Association

of Securities Dealers, Inc. and any stock exchange registered with the U.S. Securities and Exchange Commission as a

national securities exchange under the U.S. Securities

Exchange Act of 1934; and

b) [stock exchanges of the other Contracting State].
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Article 23

RELIEF FROM DOUBLE TAXATION

1. In accordance with the provisions and subject to the

limitations of the law of the United States (as it may be amended

from time to time without changing the general principle hereof),

the United States shall allow to a resident or citizen of the

United States as a credit against the United States tax on income 

a) the income tax paid or accrued to _______ by or on

behalf of such citizen or resident; and

b) in the case of a United States company owning at

least 10 percent of the voting stock of a company that is a

resident of _______ and from which the United States company

receives dividends, the income tax paid or accrued to

________ by or on behalf of the payor with respect to the

profits out of which the dividends are paid. 

For the purposes of this paragraph, the taxes referred to in

paragraphs 1(b) and 2 of Article 2 (Taxes Covered) shall be

considered income taxes.

2. In accordance with the provisions and subject to the

limitations of the law of ________ (as it may be amended from

time to time without changing the general principle hereof),

________ shall allow to a resident or citizen of_________ as a

credit against the _________ tax on income

a) the income tax paid or accrued to the United States

by or on behalf of such resident of citizen; and

b) in the case of a company owning at least

10 percent of the voting stock of a company that is a

resident of the United States and from which the 

company receives dividends, the income tax paid or accrued

to the United States by or on behalf of the payor with

respect to the profits out of which the dividends are paid.

For the purposes of this paragraph, the taxes referred to in

paragraphs 1(a) and 2 of Article 2 (Taxes Covered) shall be

considered income taxes.

3. Where a United States citizen is a resident of ________: 
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a) with respect to items of income that under the

provisions of this Convention are exempt from United States

tax or that are subject to a reduced rate of United States

tax when derived by a resident of __________ who is not a

United States citizen, _________ shall allow as a credit

against ________ tax, only the tax paid, if any, that the

United States may impose under the provisions of this Convention, other than taxes that may be imposed solely by

reason of citizenship under the saving clause of paragraph 4

of Article 1 (General Scope); 

b) for purposes of computing United States tax on

those items of income referred to in subparagraph (a), the

United States shall allow as a credit against United States

tax the income tax paid to ________ after the credit referred to in subparagraph (a); the credit so allowed shall

not reduce the portion of the United States tax that is

creditable against the ________ tax in accordance with

subparagraph (a); and

c) for the exclusive purpose of relieving double

taxation in the United States under subparagraph (b), items

of income referred to in subparagraph (a) shall be deemed to

arise in ________ to the extent necessary to avoid double

taxation of such income under subparagraph (b).
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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 that is more burdensome than the taxation and

connected requirements to which nationals of that other State in

the same circumstances, particularly with respect to taxation on

worldwide income, are or may be subjected. This provision shall

also apply to persons who are not residents of one or both of the

Contracting States.

2. The taxation on a permanent establishment or fixed base

that a resident or enterprise of a Contracting State has in the

other Contracting State shall not be less favorably levied in

that other State than the taxation levied on enterprises or

residents of that other State carrying on the same activities. 

The provisions of this paragraph 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 that it grants to its own residents. 

3. Except where the provisions of paragraph 1 of Article 9

(Associated Enterprises), paragraph 4 of Article 11 (Interest),

or paragraph 4 of Article 12 (Royalties) apply, interest, royalties, and other disbursements paid by a resident of a Contracting

State to a resident of the other Contracting State shall, for the

purpose of determining the taxable profits of the first-mentioned

resident, be deductible under the same conditions as if they had

been paid to a resident of the first-mentioned State. Similarly,

any debts of a resident of a Contracting State to a resident of

the other Contracting State shall, for the purpose of determining

the taxable capital of the first-mentioned resident, be

deductible under the same conditions as if they had been

contracted 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 that is more burdensome than

the taxation and connected requirements to which other similar

enterprises of the first-mentioned State are or may be subjected.
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5. Nothing in this Article shall be construed as preventing

either Contracting State from imposing a tax as described in

paragraph 8 of Article 10 (Dividends).

6. The provisions of this Article shall, notwithstanding

the provisions of Article 2 (Taxes Covered), apply to taxes of

every kind and description imposed by a Contracting State or a

political subdivision or local authority thereof.
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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, and the time limits prescribed in

such laws for presenting claims for refund, present his case to

the competent authority of either Contracting State.

2. The competent authority shall endeavor, 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. Any agreement reached shall be

implemented notwithstanding any time limits or other procedural

limitations in the domestic law of the Contracting States. 

Assessment and collection procedures shall be suspended during

the pendency of any mutual agreement proceeding.

3. The competent authorities of the Contracting States

shall endeavor to resolve by mutual agreement any difficulties or

doubts arising as to the interpretation or application of the

Convention. In particular the competent authorities of the

Contracting States may agree:

a) to the same attribution of income, deductions,

credits, or allowances of an enterprise of a Contracting

State to its permanent establishment situated in the other

Contracting State;

b) to the same allocation of income, deductions,

credits, or allowances between persons;

c) to the same characterization of particular items of

income, including the same characterization of income that

is assimilated to income from shares by the taxation law of

one of the Contracting States and that is treated as a

different class of income in the other State;

d) to the same characterization of persons;
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e) to the same application of source rules with respect 

to particular items of income; 

f) to a common meaning of a term;

g) to advance pricing arrangements; and

h) to the application of the provisions of domestic law

regarding penalties, fines, and interest in a manner consistent with the purposes 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 also may agree to increases in

any specific dollar amounts referred to in the Convention to

reflect economic or monetary developments. 

5. 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. 
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Article 26

EXCHANGE OF INFORMATION AND ADMINISTRATIVE ASSISTANCE

1. The competent authorities of the Contracting States

shall exchange such information as is relevant for carrying out

the provisions of this Convention or of the domestic laws of the

Contracting States concerning taxes covered by the Convention

insofar as the taxation thereunder is not contrary to the Convention, including information relating to the assessment or

collection of, the enforcement or prosecution in respect of, or

the determination of appeals in relation to, the taxes covered by

the Convention. The exchange of information is not restricted by

Article 1 (General Scope). Any information received by a

Contracting State shall be treated as secret in the same manner

as information obtained under the domestic laws of that State and

shall be disclosed only to persons or authorities (including

courts and administrative bodies) involved in the assessment,

collection, or administration of, the enforcement or prosecution

in respect of, or the determination of appeals in relation to,

the taxes covered by the Convention or the oversight of the

above. Such persons or authorities shall use the information

only for such purposes. They may disclose the information in

public court proceedings or in judicial decisions.

2. In no case shall the provisions of paragraph 1 be

construed so as to impose on a Contracting State the obligation:

a) to carry out administrative measures at variance 

with the laws and administrative practice of that or of the

other Contracting State;

b) to supply information that is not obtainable under

the laws or in the normal course of the administration of

that or of the other Contracting State;

c) to supply information that would disclose any trade,

business, industrial, commercial, or professional secret or

trade process, or information the disclosure of which would

be contrary to public policy (ordre public).

3. Notwithstanding paragraph 2, the competent authority of

the requested State shall have the authority to obtain and

provide information held by financial institutions, nominees or

persons acting in an agency or fiduciary capacity, or respecting

interests in a person, including bearer shares, regardless of any
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laws or practices of the requested State that might otherwise

preclude the obtaining of such information. If information is

requested by a Contracting State in accordance with this Article,

the other Contracting State shall obtain that information in the

same manner and to the same extent as if the tax of the firstmentioned State were the tax of that other State and were being

imposed by that other State, notwithstanding that the other State

may not, at that time, need such information for purposes of its

own tax. If specifically requested by the competent authority of

a Contracting State, the competent authority of the other

Contracting State shall provide information under this Article in

the form of depositions of witnesses and authenticated copies of

unedited original documents (including books, papers, statements,

records, accounts, and writings), to the same extent such

depositions and documents can be obtained under the laws and

administrative practices of that other State with respect to its

own taxes.

4. Each of the Contracting States shall endeavor to collect

on behalf of the other Contracting State such amounts as may be

necessary to ensure that relief granted by the Convention from

taxation imposed by that other State does not inure to the

benefit of persons not entitled thereto. This paragraph shall

not impose upon either of the Contracting States the obligation

to carry out administrative measures that would be contrary to

its sovereignty, security, or public policy.

5. For the purposes of this Article, the Convention shall

apply, notwithstanding the provisions of Article 2 (Taxes Covered), to taxes of every kind imposed by a Contracting State.

6. The competent authority of the requested State shall

allow representatives of the applicant State to enter the

requested State to interview individuals and examine books and

records with the consent of the persons subject to examination.
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Article 27

DIPLOMATIC AGENTS AND CONSULAR OFFICERS

Nothing in this Convention shall affect the fiscal privileges of diplomatic agents or consular officers under the general

rules of international law or under the provisions of special

agreements.
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Article 28

ENTRY INTO FORCE

1. This Convention shall be subject to ratification in

accordance with the applicable procedures of each Contracting

State. Each Contracting State shall notify the other as soon as

its procedures have been complied with. 

2. The Convention shall enter into force on the date of the

receipt of the later of such notifications, and its provisions

shall have effect: 

a) in respect of taxes withheld at source, for amounts

paid or credited on or after the first day of the second

month next following the date on which the Convention enters

into force;

b) in respect of other taxes, for taxable periods

beginning on or after the first day of January next following the date on which the Convention enters into force.
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Article 29

TERMINATION

1. This Convention shall remain in force until terminated

by a Contracting State. Either Contracting State may terminate

the Convention by giving notice of termination to the other

Contracting State through diplomatic channels. In such event,

the Convention shall cease to have effect:

a) in respect of taxes withheld at source, for amounts

paid or credited after the expiration of the 6 month period

beginning on the date on which notice of termination was

given; and

b) in respect of other taxes, for taxable periods

beginning on or after the expiration of the 6 month period

beginning on the date on which notice of termination was

given.

IN WITNESS WHEREOF, the undersigned, being duly authorized

thereto by their respective Governments, have signed this

Convention.

DONE at in duplicate, in the English and 

languages, both texts being equally authentic, this day of 

(month) , 19 .

FOR THE UNITED STATES FOR: 

OF AMERICA: