(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 are or may be subjected.
(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) Notwithstanding the provisions of paragraph (2) of this
Article, where a company which is a resident of one of the
Contracting States, having a permanent establishment in the other
Contracting State, derives profits or income from that permanent
establishment, any remittance of such profits by the permanent
establishment to a resident of the first-mentioned Contracting
State may be taxed (in addition to the tax which would be
chargeable on those profits if they were the profits of a company
which was a resident of that other Contracting State) in accordance
with the law of the other Contracting State, but the rate of tax so
imposed shall not exceed 10 per cent of the amount of these profits
remitted or deemed to be remitted.
(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 that first-mentioned State are or may be subjected.
(5) Except where the provisions of Article 9, paragraph (7)
of Article 11 paragraph (7) of Article 12, or paragraph (6) of
Article 13 apply, interest, royalties, technical fees 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 firstmentioned State.
(6) Nothing contained in this Article shall be construed as
obliging either Contracting State to grant to individuals not
resident in that State any of the personal allowances, reliefs and
reductions for tax purposes which are granted to individuals so
resident.
(7) In this Article the term `taxation` means taxes of every
kind and description.
