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432 ΕΠΙΣΗΜΟΣ ΕΦΗΜΕΡΙΣ ΤΗΣ 7ης ΜΑ'Ι'ΟΥ 1982
(b) Ho\vever, such remuneratio~ shall b.e Ι paid is ef~ectively ooru;ιected with such perma_
taxable only in the other Contracωιg State lf Ι nent establtshment or fixed base. Ιη sudι case,
the services are rendered· in that State and the the provisions αf Article 7 or Artiole 14 as the
jndividual is a resident οί that State who- case ffi'ay 00. s'hall apply. '
(ί) is a national of t1Iat State; or
(ίί) did not beoome resident οί that S,tate
solely for the puφose οί rendering the
serνlces.
2. (a) Any pension paid by, or ου1: οί funds
created by. a Contraoting State or a political
subdiνision or a loca1 authority th~roof to an
individual ίη respect οί serνices rendered to that
State or subdίvisιion or authority shall be taxable
οηlΥ ίη that S-ta,te.
(b) However, such pens,ion shall 00 taxable
οηlΥ ίn the σther ContracJting State if the indi–
vidual is a resident οί and a na:bional οί th-at
State.
3. The proV'isions οί A:rticles 15, 16 and 18
shall applyto remuneration and pensions ίη
respect οί serνices rendered ίη CiOηηoo~ίoη wiιth
a business or industrial aotivities carried οη by
.a CΌntracJting State or apolIitical subdJivision or
a local auΙhοrίtΥ ιtheroof.
Article 20
STUDENTS
1. Payments which a S'tud'ent or an apprerrtice
who is or was munedia!tely before visiting a Con–
tracti ng Stare a residenIt οί the other Oontracιting
State and who is present ίη the rurSlt-mentioned
State solely for the purpose οί his educaJtion or
training receives for the purpose οί h:is mainie–
nance, education or tΓaίηίηg sh'aH ηοιΙ Ibe taxed
ίη that State, provided that such payments arise
from sources ouιtside that Suate.
2. Notwirthstanding th~ p-rovisions οί Articles
14 and 15 a S'tudent or 'an apprenuice who is or
was immedJi·ately befure vi'siιting a Oontracting
State a resident σf the dther State and who i,s
present ίη the first S,ta;te solely for ιthe pu,rp'OSC;
of h is educa:tion or tra:ining sh'aH ηαt be taxecl
ίη the f.irst Statc ίη respeot οί remuneratιΪ'on for
services rendered ίη the first State, provid'ed that
the serνices are ίη conneotlion wiιth his stud,ies
0:- training or the remuneration of the serνices
const~tutes eamings necessa:ry for his ffiaJin!tenance,
,studies and train:ing.
Article 21
TEACHERS
Remuner3!tΪon received for OOυσaϋίoη or scien–
tific resea:roh by an indiv:idual who is or was
immedιiarely before v,isiting a Con!tracti.ng S:ta.te
a resident οί the other Comraoting Staιte and
who is presenιt ίη the first State for the Ρuφοse
σf scientific research or for tea.ching at 'a univer–
sity, 00 Hege. establishment for higher educaltJΪon,
or at a similar estιblishment shall 00 exempt
from tax ίη the first State proνtided that such
·establishment be]ongs to non-profit making legal
entities.
Article 22
OTHERINCOME
1. Items οί income of a resident οί a Οοη­
'traoting State. wherever arisίng, ηοΙ dea.lιt with
ίη the foregσίng Articles af th,is Convention shall
be taxable only ίη that State.
2. The provisions οί pamgraph 1 shall not
apply to income, other than income from immov–
able propert:y as defined ίη paragraph 2 οί Article
6. ίί ιthe recipient of such inoome, beίng a resi–
,dent af a G>ntractmg State, cames οη business
ίη the other Contraσting State through a peιma­
nent establίshment si,tuated therein, or performs
ίη that other State independent personal services
from a fixed base situated thereίn, and the ήght
ιOr property ίη respect of wh.ich the inooιne is
Article 23
CAPITAL
1. Capital represented by immovable pro–
perty, referred to ίη Article 6, owned by a resident
οί a Contracting State and situated ίη the other
Contracting State, may 00 taxed ίn that other
State.
2. Capital represented by movable property
forming part οί the business property of a per–
manent establishment which aπ enterprise οί a
Contractίng State has ίη the other Contracting
State or by movable property pertaining to a
fixed base available to a resident of a Contract–
ing State ίη the other IContracting State for the
purpose of performing independent persona]
serνices, m'a Υ be taxed ίη that other State.
3. Capital represenood by ships, boats, engaged
ίη inland waterways, aircraft or road transport
vehicles operated ίη intemational traffic, and by
movable property pertaining to the operation of
such ships, boats, aircraft or vehicles shall be
taxable OnlY ίη the Contracting State ίη which
the place οί effective management of the enter–
prise is situated.
4. ΑΠ other elements οί capita1 of a resident
οί a Contracting State shall be taxable only in
that State.
Article 24
ELIMINATION OF DOUBLE ΤΑΧΑΤΙΟΝ
The double taxation shall be eliminated as
follows:
(a) Ιη the Hungarian People's Republic:
(ί) Where a ,resident οί the Ηuηgaήan
People's Republic deήves ίncome or
owns capital which, ίη accordance
with the provisions οί this Conven–
tion may be ιtaxώ in the Republic
of Cyprus, the Hungarian People's
-Republic shall, subjectto the pro–
visions of 'subparagraph,s (ίί) and
(ili), exempt such income or capital
from tax.
(ίί) Where a resident οί the Ηuηgaήan
People's Republic derives items of
'income which, ,ίη accordance with
the provisions of Articles 10 and 11,
may be taxed ίη the Repu.blic οί
Cyprus, the Hungariao People's Re–
public shall allow as a deduction
from the tax οη the income οί that
resident an amount equal to the tax
paid ίη the Republic of Cyprus.
Such deduction shall not, however,
exceed that part οί the tax, as
computed before the deduction is
given which is attήbutabΙe to such
items οί income derived from the
Repub1ic of Cyprus.
(ili) Where ίη accordance with any pro–
visions οί the Convention income
derived or capita1 owned by a re–
sident of the Ηungaήaη People's
Republic i,s exempt from tax in the
Ηungaήan People's RepubIic, the
Ηungaήan Poople's Republjc may
nevertheless, ~ ίη calculatίng the
amount of tax οη the remaining ίη­
come or capiιta:1 οί such resident,
take ίηto accσunt the exempted ίη­
come or capital.
(b) ίη the Repub1icof Cyprus:
Subject to the provisions οί Cyprus Tax
Law regarding credit for foreign tax,