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ΕΠΙΣΗΜΟΣ ΕΦΗΜΕΡΙΣ ΤΙ-ΙΣ 26ης ΝΟΕΜΒΡΙΟΥ 1982 1067
to the performance of such traffic operations
and ίί they are paid Ιο persons other t'hIan
residents of the State where the pennanent
establis'hment is situated;
(ί) salary or wages paid Ιο persόnnel of a per–
manent estabHsh'ment of tourist orgariiza–
tions if these remunerations are paid to
persons other than residents of the State
where the permanent establίSιhment is
situated;
(g) income received from tour ,performances
and other publίc perfoπnances;
(h) sums of prizes. prem'iu'ms and remunerat'ions
paid to participants and winners of sportive
and other perfonnances and competitions;
(ί) sums paid as compensation for damage or
injury caused.
3. Αη individual who is a resident of a Contract–
ing State shall ηοΙ be deemed ιο be a resident of
the other Contracting SΙate by mere reason that
he performs any of the activities enumerated ίη
paragraph 2 οη the territory of that other State.
4. Ιη the application of the provisions of para–
graphs 1 and 2. taxes sh:all be imposed οη the
basis οί income received by individuals after the
date οΙ eΧΡίratίόη σf maximum favourable terms
mentίoned ίη paragraphs 1 and 2.
Article 12
Government Employees
1. Salaries. wages and other similar remunera–
ιίοη οΙ a resident οΙ a G>ntracting State ίη respect
of work ίη government agenc'ies or esta,blishments
οΙ th'is State ίη the discharge of functions of a
govemmental character. ίη the territory οί the
other Contracting State. provi'ded they are re–
oognized as stIch under tIle laws of the first–
mentioned State. shall O'ot be lίable Ιο taxation ίη
the other State.
2. Pensions. benefits and other similar remune–
ration of a resident οΙ a Contracting S'tate ίη consi–
deration for past em,ployment ίη governmental
functions mentioned ίη paragraιph 1, ίη respect of
'work or employment ίη government agencies or
estaιblishments of this State, shaH ηοΙ be 1iaJble to
taxation ίη the other State.
Article 13
Other IO'come
Categories of income ηοΙ enumerated ίη the
foregoing articles of this Convention received by
a resident of a Contracting State from sources ίη
the other Contracting State shaH ηοΙ be liaIble to
taxation ίη that other State.
AIΨicle 14
Special Tax Privileges
1. The provisions of this Convention shall ηο!
affect tax privileges of foreign diplomatic and
consular missions. other establishments and orga–
nizations of the Contracting SVates which enjoy
equality therewith ίη respect of tax privileges, the
heads and mem,bers of the dipl'σmatic personncl
and staff of those missions, institu'tions and orga–
nizations, and also members of their famHies.
2. The provisions of paragraph 1 sh'all alsa
aιρρ]y to reΡreseηιatίνes, members of parliamentary
or governmental delegations and also employees
of the delegations of the Contracting States who
arrive ίη one of these States Ιο participate ίη inter–
governmental negotiations, international confe–
rences or meetings, or οη other off'iciaιl missions.
Article 15
Non-Discri,mination
]. The citizens of a Contracting State shalI ησΙ
be subjected ίη the other Contracting State to
higher or more buroensome taxati'OD than citi·
zens of tha't other Sta'te ίη the same circumstances.
2. The taxation of a res'ident οί a Contractίng
State who has a p~rmanent esta'blis'hment ίη t'he
other Contracting State shall not be less favour..
able than the tax~tion of residents of a third Sta,tt;
having perm'anent esta1bHshment ίη that oth~r.
State.
3. The provisions of paragraphs 1 and 2 shall
ηοΙ be construed as obliging a 'Contracting State
ιο grant Ιο res'idents of the other Contracting State
tax reliefs which are granted Ιο its own resident&
or Ιο resi'dents of a th'ird State ίη acoordance with
special agreements with th'at third State.
Article 16
CοηdίrίΌηs of Application σf
the Convention
Ι. 'Jlhis Convention shall apply ιο the taxatioIJ
of income derived solely from such activity as is
carried οη ίη a ContraC'ring State ίη conformity
with the laws and regulations ίη force ίη that
Statc.
2. The provisions of this Convention shal'l η9Ι
affect existing agreements govern'ing questions οί
taxation which were previously concluded bet–
ween the Contracting States. Hσwever. where this
Conven'tion provides for a more faVQuraιble taxa,..
ιίοη treatment, the provisions οί this Convention
sh'all prevail.
Article 17
Exchcιnge Όί Infunnation
Τhe competent auΙhΌrίtίes of the Contracting
States shall, to the exten't permitted by their laws,
exchange such infoπnation 'as is necessary οη
changes ίη their tax laws, and also υ'ροη request
any other material required for the carrying out
of this Convention. ΑηΥ such informa1ion or
ma terial s'hallbe treated as confidential and shall
be used solely for purρoses connected with the
implementation οί thIis Convention.
Article 18
Settlement of Disρutes
1. Where a resident of a Contracting State
considers that the actίΌηs of one or both Contract–
ing States result or will result for him ίη taxation
ηοΙ ίη acoordance with this Conven'tioD, he m:ay,
notwitllstanding the remediesprovided by the
l'aws of the Contracting Sta'te of which he is a resi–
dent, present his cla'im Ιο the competent authΌrί­
ties of that State. Should the comιpetent authorj–
ties which receive the claim deem ίι justified, they
shall endeavour ιο reaC'h agreement with the
competent au-thorities of the other Contracting
State with a view Ιο aroid'ing taxation not ίη
accordance with th'is Conven'tion.
2. Should such ,an agreement be reached. the
com,petent authorities of the appropriate Contract–
ing State sha:l1, if necessary. refund the ovetpay–
ment, grant tax privileges or coHect taxes.
3. The competent aut'horities οί the Con'tract..
ing States shall endeavour Ιο resolve by mutua1
agreement any difficul'ties arising ίη the course
of the application of this Convention. They may
also discuss together the possibility of double
taxation avoidance ίη cases ηοΙ provided for ίή
this Convention.
Article 19
ΕηΙΓΥ ίηΙο Force of theConvention
1. The Contracting States shaJιl notify ea~h
other through d'iplomatic channels οί the comΡΙό­
ιίοη of tlle formalities necessary for the entry into
force of this Convention.
2. Τhis Convention shal1 enter ίηto force after
ΙΙ1σ expiration of 30 days following the date οη