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426
ΕΠΙΣΗΜΗ ΕΦΗΜΕΡΙΔΑ ΤΗΣ Αης ΑΠΡΙΛΙΟΥ
1984
(6)
Income received by an individual for
his
performance
ο!
labor or personel
serνices,
whether
ββ βη
employee or
ίη βΩ
independent capacity, shall be treated
Βθ
income from
sources within a Contracting State only to the extent that
such
serνices βΤθ
perforn"ied
ίη
that Contracting State.
Notwithstanding the preceding sentence, income from personal
serνices
performed aboard ships
οτ
aircraft operated by a
resident of a Contracting State
ίη
international traffic
ehall be treated
βθ
income from sources only within that
Contracting State if rendered by a member of the regular
oomplementof the ship or aircraft. For the purposes
ο!
this
paragraph, income from labor
οτ
personal services includes
peneions (as defined
ίη
paragraph
(3)
ο!
Artic1e
23
(Private
Pensions and Annuities» paid
ίη
respect
ο!
such
serνices.
Notwithstanding the preceding
ρτονίθίΟΩΒ ο!
this paragraph:
(a) Remuneration described
ίη ΑτΙίοlθ
22 (Governmental
Functions)and payments described
ίη
Artic1e 24
(50cia1 Security Payments) shall be treated
βθ
income
from sources within a Contracting State on1y
ί!
paid
by
οτ
from the public funds
ο!
that Contracting
Stete or a political subdivision
οτ
100a1 authority
thereof; and
(b) The
ροτΙίΟΩ ο!
directors' fees taxable in a
Contracting 5tate under Article
20
(Directors' Fees)
shal1 be treated
θ8
income from sources within such
Contracting State.
(7)
Income from the purchase and sale
ο!
intangible
οτ
tangib1e persona1 (including movable) property (other than
Ββίηθ
defined
8Β
royalties by paregraph (2)(b)
ο!
Article 14
(Royalties» shall be treated
88
inoome from sources within
a Contracting State only if such property is either so1d
ίη
that Contracting State
οτ
is property described in paragraph
(1)(a) or (b)
ο!
Article 16 (Gains) and the real property
i8
10cated
οτ
deemed to be located
ίη
that Contracting State.
(8)
Notwithstanding paragraphs (1) through
(7),
industrial
or commercia1 profits which are attributab1e to a permanent
establishment which the recipient, a resident
ο!
a
Contracting State, has
ίη
the other Contracting state,
1~cluding
income derived from rea1 property and natura1
resources and dividends, interest, royalties (as defined
ίη
paragraph (2)
ο!
Article 14 (Royalties», and gains, but