Note: This Treaty may be impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). MLI impact on Tax Treaties is available with the Orbitax International Tax Research & Compliance Expert.
ARTICLE 27
Income of Government and Institutions
The Federal or the Local Governments and the financial institutions which are wholly owned by one of the Contracting States shall be exempt from tax in the other Contracting State in respect of any income or capital gains derived by such federal or Local Government from that other Contracting State except income from hydrocarbon as stated in Article 3, income from immovable property as stated in Article 7 and capital gains on immovable property as stated in Article 14 paragraph (1) and (4).