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2.Where in accordance with any provision of this Convention income derived by a resident of a Contracting

State is exempt from tax in that State, such State may nevertheless, in calculating the amount of tax on the

remaining income of such resident, take into account the exempted income.

CHAPTER V

SPECIAL PROVISIONS

ARTICLE 23

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, which is other or more burdensome than the taxation and connected

requirements to which nationals of that other State in the same circumstances, in particular with respect to

residence, are or may be subjected. This provision shall, notwithstanding the provisions of Article 1, also apply

to persons who are not residents of one or both of the Contracting States.

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. This provision 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 which it grants to its own residents.

3. Except where the provisions of paragraph 1 of Article 9, paragraph 7 of Article 11, paragraph 6 of Article

12, or paragraph 3 of Article 21, apply, interest, royalties 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

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 which is other or more burdensome than the

taxation and connected requirements to which other similar enterprises of the first-mentioned State are or may

be subjected.

5. The provisions of this Article shall, notwithstanding the provisions of Article 2, apply to taxes of every kind

and description.

ARTICLE 24

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, present his case to the competent authority of the Contracting

State of which he is a resident or, if his case comes under paragraph 1 of Article 23, to that of the Contracting

State of which he is a national. The case must be presented within three years from the first notification of the

action resulting in taxation not in accordance with the provisions of the Convention.

2. The competent authority shall endeavour, 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 in the domestic law

of the Contracting States.

3. The competent authorities of the Contracting States shall endeavour to resolve by mutual agreement any

difficulties or doubts arising as to the interpretation or application 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 of the Contracting States may communicate with each other directly, including

through a joint commission consisting of themselves or their representatives, for the purpose of reaching an