(1) The 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:
Provided that this paragraph shall not prevent the
Government of a Contracting State from imposing on the profits
attributable to a permanent establishment in that Contracting State
of a company which is a resident of the other Contracting State an
additional tax not exceeding 15 per cent of two-thirds of the
profits of the permanent establishment after payment of the company
or corporation tax on those profits.
(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 firstmentioned State are or may be subjected.
(4) 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, nor as conferring any exemption from tax in a Contracting
State in respect of dividends paid to a company which is a resident
of the other Contracting State.
(5) In this Article the term `taxation` means taxes which
are the subject of this Convention.
