Page 436 - ΔΟΚΙΜΗ

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ΕΠΙΣΗΜΗ ΕΦΗΜΕΡΙΔΑ ΤΗΣ 4ης ΑΠΡΙΛΙΟΥ
1984
427
oΩl,
1t
the property or rights giving rise to such lncome,
41~1d.nde,
lnterest, roya1tles, or galne are effectlve1y
OOΔnected
wlth
Buch
permanent estab1ishment, sha11 be
treated
βS
income from sources wlthin that other Contracting
8t.t.e.
(9)
The BOUl"ce
ο!
any i
tem
ο'!
income to which paragraphs (1)
through
(8)
are not applicable shal1 be determined by each
ο!
the Contracting States
ίη
accordance with its
οννη
1aw.
Notwithstanding the
precediηg
sentence, if
t~e
source
ο'!
at13
i tem
ο!
income under the 1av,s
ο! οηθ
Contracting Stete
is different from the source of such item
ο!
lncome under
the 1aws of
tl~e
other Contracting State or if the source
of such income is not readi1y deternIinab1e under the laws
ο'!
a
Contractiηg
State, the competent authorities
ο!
the
Contracting Stetes
may,
ίη
order to prevent double taxation
or further any other J:urpose
ο'!
this Convention, establish
a common source
ο'!
the item
ο!
income for the purposes
ο'!
this Convention.
Article
7
NON-DISCRIMINATION
(1)
Α
citizen of a Contracting State shall not be subjected
in the
otl~er
Contracting State to more burdensome taxes than
a citizen
ο!
that other Contracting State who 1s in similar
circumstances. For purposes of United States taxation,
United States citizens who are not resident in the United
States and Cypriot citizens who are not resident
ίη
the
United Stetes are not
ίη
simi1ar
circ~stances.
(2)
Α
permanent establishment which a resident of · a
Contracting State has
the other Contracting State shall
not be eubject
ίη
that other Contracting State to more
burdensome taxes than a resident of that other Contracting
State carrying
οη
sinlilar activities. This paragraph sha11
not be construed
βΒ
ob1iging a Contracting State to grant
to individual residents of the other Contracting 5tate any
personal a11owances, reliefs, or deductions for taxation
purposes
οη
account of
cίνί1
status or family responsibilitiee
which it grants to its
οννη
ind1vidua1 residents.
(3)
Except where the provisions of paragraph 1 of Article
11 (Related Persons), pare.graph
5
ο!
Article 13 (Interest),.