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ΕΠΙΣΗΜΗ ΕΦΗΜΕΡΙΔΑ ΤΗΣ 14ης ΙΑΝΟΥΑΡΙΟΥ
1983
IS
:
3. Gains from the
alienatίon οί
any property
ot}1er than those mentioned
ίη
paragraphs 1 and
2.
shall be taxable only
ίη
the Contracting State
of
wl1ίch
the aJienator is a resident.
Article
22
Elimination
οί
Double Taxati'On
Where income
deriνed
from one of the
Contracting States. is subject
Ιο
tax
ίη
both Con–
tracting States. relief from
tax
attributable '
Ιο
suchincome shal1 be given
ίη
accordance with
the domestic laws and regulations
οί
the Contract–
ing States.
Artίcle
23
Νοη-
Discrimination
1.
Persons of the Cootracting State
as
defined
under Article
3
shall
ηοι
be subjected
ίη
the
other
Contractίng
State
Ιο
any
taxatίon
or any
requiremeot connected therewith. which is other
or more burdensome than the
taxatίon
and
connected requirements
Ιο
which persons of that
other State
ίη
the same circumstances are or may
be subjected.
2.
The taxation of a
ρermanent
estab1ishment
which an
eηterpήse
of a Contracting State has
ίη
the other Contracting State shall
ηοΙ
be
Iess
faνourably leνied ίη
the other Contracting State
than the taxation levied
οη enterpήses
of that
other Contracting State carrying
οη
the same
activities. The
proνision
shall
ηοι
be construed
as
obligίng
a Contracting State
ιο
grant
Ιο
resi–
dents
οί
the other Contracting State legally fixed
persona1 allowances. reIiefs and
reductίons
which
ίι
grants
Ιο
its own residents.
3.
Εnterpήses
of a Contracting State. the ca–
pita1 of which is wholly or partly owned or
controlled.
dίrectIy
or indirectIy by one or more
residents of the other Contracting State. shall
ηοΙ
be subjected
ίη
the first-mentioned Contract–
ing State
Ιο
any taxation or any requirement
connected therewith which is other or more bur–
densome than the taxation and connected re–
quirements to which other similar enterprises
οί
the first-mentioned State are or may be sub–
jected.
Article
24
Mutual Agreement Procedure
1.
Where a resident
οί
a Contracting State
considers that the actions of one or both
οί
the
Contractίog
States have resulted or will resuIt
for
him
ίη
taxation
ηοΙ ίο
acoordance with the
proVΊsions
of this
Conνention.
he may present
his case
Ιο
the competent authority
of
the Con–
tracting State
οί
which he is a resident.
2.
The competent
authοήtΥ
sha'll endeavour,
ίf
the objection appears
Ιο ίι
to be
justίfied. Ιο
re–
solνe
the case by mutual agreement with the
comρetent
authority of the other
Contrac~ing
State. with aview
Ιο
the avoidance of taxation
which is
ηοΙ ίη
accordance with the Convention.
3. The competent
authοήties οί
the Contract–
ing Statesshall endeavour 'to resolve by mutual
agreement
aήΥ
problems arising
as
Ιο
the inter–
pretation or application of the Convention. They
For
the
Government
of
the
'Republic
of
Cyprus.
Ν. Α.
ROLANDIS
mayalso consult together for the elimination of
double taxation
ίη
cases
ηοΙ proνided
for
ίη
the
Conνent1on.
4.
Tl1e competent a'uth'Orities
οί
the Contract–
ing States may communicate with each other di–
rectly for the purpose of reaching an agreement
ίο
the sense of the preceding paragraphs. Where
ηο
agreement
as
Ιο
open questions can be reached.
a commission composed
οί
an equal number of
representatiνes
of the competent a'uthoritie$
of
either Contracting State may be
esta:bJίshed. wJ;ιich
is
Ιο
meet upon the request of one Contracting
State.
Article
25
Exchange
οί Inforιnation
The competent authorities of the Contracting
States shalI exchange such information
as
is ne–
cessary for carrying
ουΙ
the
proνisions οί
this
Convention and especialIy of the domestic laws
of the Contracting States conceming taxes
coνer
ed by the
Conνention.
The exchanged
ίnforma
ιίοη
shaH be treated as secret and disclosed onIy
Ιο
persons
inνolved ίη
the assessrnent or col–
lection of the taxes
coνered
by the
Conνention.
ArticIe
26
Diplomatic Agents and Consu1ar Officers
Nothing
ίη
this
Conνention .
shall affect the
fiscal
priνileges
of the staff of diplomatic and
consular missions under the generaI1y accepted
ru les of intemationaI Iaw
οι
under the
proΝΊSions
of speciaI agreements.
Artic]e
27
Entry
ίηΙο
Force
1.
This
Conνention
shall be
ratίfied
or ap–
proνed ίη
accordance with the Iaws valid
ίο
the
two Contracting States.
2.
The
Conνention
shalI
enter into force upon
exchange
οί
notes notifying the
approνaI
or rati–
fication of the Convention
ίο
accordance
WΊth
νa1id
Iaws.
3. The
proνisions
of the Convention shall apply
ιο
taxes
coνered
by this Convention
whίch
are
leνied
for any year
beginnίng οη
or after 1st
January.
1983.
Article
28
Period
of
ν
alidity
This
Conνention
is concluded for unlimited
duration. Either Contracting State may terminate
the
Conνention
by
giνing
written notice after five
years from the day
οί
its entry
ίηΙο
force. how–
eνer.
at least six months before the end of the
current calendar year.
In such event. the Convention shall cease to
have effect for taxes covered by the Convention
for the assessment
Ρeήοd
folIowing
termίnation.
Ιη
witness whereof the
ΡΙeniΡοtentiaήes οί
the
two Govemments have signed
thίs
Convention.
Done and signed at Nicosia
οη
the 16th
October
1982
ίη
two
οήginals ίη
the
English
Janguage.
For the Government
of the
Gennan Democratic Republic.
OSKAR FISCHER