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422
ΕΠΙΣΗΜΗ ΕΦΗΜΕΡΙΔΑ ΤΗΣ 4ης ΑΠΡΙΛΙΟΥ
1984
Article
4
GΕ~ΈRΑL
RULES OF
ΤΑΧΑΤΙΟΝ
(1)
Α
resident
ο!
a
Contracting State may be taxed by
the other Contracting State
ΟΩ
any income from sources
within that other Contractihg state and only
οη
such
income, subject to any limitations set forth
ίη
this
Convention. For
tΙίs
purpose, the rules set forth
ίη
Article
6
(Source
ο!
Income) shall be applied to
detern,ine the source
ο!
income.
(2)
The
pToν~θ1.oηB
of t11is Convention shal1 not be
construed to restrict
ίΩ
any manner any exclusion, exemption,
deduction, credit,
οτ
other al10wance now or hereafter
8ccorded:
(a)
ΒΥ
the 1aws
ο!
a Contracting State
ίη
the
deterπline.tion
of tl)e tax imposed
by
that
Contracting 8tate; or
(b)
ΒΥ
any
other agreement between the
Contracting States.
(3)
Wotwithstanding any prOV1.S10nS
ο!
this Convention
8X08it
parbgraph
(4)
of this Article, a Constracting
It&te 881
tax
a
citizen
οτ
resident
ο!
that Contracting
8tat.
&8
Ι!
thi5 Convention
had
not come into effect.
hr
tb1. pu.rpose the term "citizen" shal1 include a
~oraer
cit1zen whose 105S
ο!
citizenship had
βθ οηθ
of
ιι
••
r1nclpal
purposes the avoidance of tax, but only
tor •
»eriod
οΙ
10
,ears following such
1088.
(4)
The provisions of paragraph
(3)
sha11 not affect:
(a) The benefits conferred
by
a
Contracting State
under Articles
5
(Relief from Double Taxation),
7
(Non-Discrirnintation),
24
(Social Security
Payments), and
27
(Mutual Agreement Procedure);
and
(b) The benefits conferred by a Contracting state
unuer Artic1es 21 (Students and Trainees)
and
22 (Governmental Functions) upon individuals who
are neither citizens of,
nor
have immigrant status
in,that Contrs cting State.