ARTICLE 27
Diplomatic and Consular Officials
(1) Nothing in this Convention shall affect the fiscal privileges granted to the members of a diplomatic mission or consular post under the general rules of international law or under the provisions of special agreements.
(2) In so far as, owing to fiscal privileges granted to the members of a diplomatic mission or consular post under the general rules or international law or under the provisions of special international treaties, income or capital is not subject to tax in the receiving State, the right to tax shall be reserved to the sending State.
(3) For the purposes of this Convention, persons who are members of a diplomatic mission or consular post of a Contracting State in the other Contracting State or in a third State and who are nationals of the sending State shall be deemed to be residents of the sending State if they are liable therein to the same obligations in respect of taxes on income and capital as are residents of that State.
(4) This Convention shall not apply to international organizations, to organs or officials thereof and to persons who are members of a diplomatic mission or consular post of a third State, being present in a Contracting State and not treated in either Contracting State as residents in respect of taxes on income and capital.