51 | II Série A - Número: 053S1 | 23 de Dezembro de 2014

a
Article 22
Other income
1 — Items ofincome of a resident of
a Contracting State,
wherever arising, not dealt with
jn the foregoing articlesof
this Convention shali be taxable
onlyin that Stãte.
2 — The provisions of paragraph 1 shall
not apply to
incorne, other than incorne
from irnmovable property as
defined in paragraph 2 ofarticie 6,
ifthe recipient ofsuch
income, being a residem
of. a Contracting State,
carnes
on business in the other
Contracting State through a
per
manent establishment situated
therein, or performs in that
other State ndependent
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 establishm.ent
or fixed base. In such case
the provisions of article 7
or article 14, as the case
may
be, shall appy.
CHAPTERIV
Elimination of double taxation
Article 23
Elimination ofdoubk taxalion
1 — Where a resident of
a Contracting State
derives
income which, in accordance
with thé provisions of
this
Convention, may be taxed
in the other-ContiactingState,
the flrstrnentionedState shall
allow, as a dduction from
the tax on the income of
that resideiit, an amount
equal
tothe income tax paid in that
other State. Such deduction
shall nót, howevêr, exceed that
part of the iiicorre tax. as
computed before thé
deduction is given, which is atfributa
ble tõ the incorne which may
be taxed in that other State.
2 Where iii accordance
with any prnvision of
this
Conventionincome derived by
a resident of a Contraë
ting State is exempt
from tax in that State,
such State
rnay nevertheless, in caiculating
the amount oftax on th
remaining income of such resident,
take into account the
exempted income.
CHAPTER V
Special provisions
Anicle 24
Non-discrimination
1 — Nationais of a Contracting
State shall not be sub
jected in the other Contracting
State to any taxation orany
requirement connectedtherewith,
which is otheror more
burdensome than the txation
and ccnnected iequitëments
to which nitiona1s ofthat
óther State in the sárne
cfrcu
mstances, in particular with respeet
to residence, are or
may’ be subjected. This
provision shali, notwithstanding
the provisionsofarticle
1, also apply to persons whoare
not residents of one or
both õf tl’e Contracting
States.
50
DAR II Série A / 51

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