MODEL CONVENTIONWITH RESPECT TO TAXESON INCOME AND ON CAPITALTITLE AND PREAMBLECHAPTER IScope of the ConventionArt. 1 Persons CoveredArt. 2 Taxes coveredCHAPTER IIDefinitionsArt. 3 General definitionsArt. 4 ResidentArt. 5 Permanent establishmentCHAPTER IIITaxation of incomeArt. 6 Income from immovable propertyArt. 7 Business profitsArt. 8 Shipping, inland waterways transport and air transportArt. 9 Associated enterprisesArt. 10 DividendsArt. 11 InterestArt. 12 RoyaltiesArt. 13 Capital gainsArt. 14 DeletedArt. 15 Income from employmentArt. 16 Directors feesArt. 17 Artistes and sportsmenArt. 18 PensionsArt. 19 Government ServiceArt. 20 StudentsArt. 21 Other incomeCHAPTER IVTaxation of capitalArt. 22 CapitalCHAPTER VMethods for elimination of double taxationArt. 23 A Exemption methodArt. 23 B Credit methodCHAPTER VISpecial provisionsArt. 24 Non-discriminationArt. 25 Mutual agreement procedureArt. 26 Exchange of informationArt. 27 Assistance in the collection of taxesArt. 28 Members of diplomatic missions and consular postsArt. 29 Territorial extensionCHAPTER VIIFinal provisionsArt. 30 Entry into forceArt. 31 TerminationTITLE OF THE CONVENTIONConvention between (State A) and (State B)with respect to taxes on income and on capital1PREAMBLE TO THE CONVENTION21. States wishing to do so may follow the widespread practice of including in the title areference to either the avoidance of double taxation or to both the avoidance of doubletaxation and the prevention of fiscal evasion.2. The Preamble of the Convention shall be drafted in accordance with the constitutionalprocedure of both Contracting States.CHAPTER ISCOPE OF THE CONVENTIONArticle 1PERSONS COVEREDThis Convention shall apply to persons who are residents of one or both of theContracting States.Article 2TAXES COVERED1. This Convention shall apply to taxes on income and on capital imposed on behalfof a ContractingState or of its political subdivisions or local authorities, irrespective of themanner in which they are levied.2. There shall be regarded as taxes on income and on capital all taxes imposed ontotal income, on total capital, or on elements of income or of capital, including taxes ongains from the alienation of movable or immovable property, taxes on the total amounts ofwages or salaries paid by enterprises, as well as taxes on capital appreciation.3. The existing taxes to which the Convention shall apply are in particular:a) (in State A): .b) (in State B): .4. The Convention shall apply also to any identical or substantially similar taxes thatare 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 eachother of any significant changes that have been made in their taxation laws.CHAPTER IIDEFINITIONSArticle 3GENERAL DEFINITIONS1. For the purposes of this Convention, unless the context otherwise requires:a) the term person includes an individual, a company and any other body ofpersons;b) the term company means any body corporate or any entity that is treated as abody corporate for tax purposes;c) the term enterprise applies to the carrying on of any business;d) the terms enterprise of a Contracting State and enterprise of the other ContractingState mean respectively an enterprise carried on by a resident of a ContractingState and an enterprise carried on by a resident of the other Contracting State;e) the term international traffic means any transport by a ship or aircraft operatedby an enterprise that has its place of effective management in a ContractingState,except when the ship or aircraft is operated solely between places in the otherContractingState;f) the term competent authority means:(i) (in State A): .(ii) (in State B): .g) the term national, in relation to a ContractingState, means:(i) any individual possessing the nationality or citizenship of that ContractingState; and(ii) any legal person, partnership or association deriving its status as such fromthe laws in force in that ContractingState;h) the term business includes the performance of professional services and of otheractivities of an independent character.2. As regards the application of the Convention at any time by a Contracting State, anyterm not defined therein shall, unless the context otherwise requires, have the meaning thatit has at that time under the law of that State for the purposes of the taxes to which theConvention applies, any meaning under the applicable tax laws of that State prevailing overa meaning given to the term under other laws of that State.Article 4RESIDENT1. For the purposes of this Convention, the term res