ARTICLE 47
Diplomatic Agents and Consular Officers
(1) Nothing in this Convention shall affect the fiscal privileges of diplomatic agents, consular officers and officials of international organizations under the general rules of international law or under the provisions of special agreements.
(2) If items of income or property are not taxed in the receiving State on account of such privileges, the sending State shall be entitled to levy tax.
(3) Notwithstanding the provisions of Article 4, an individual who is a diplomatic agent, a consular officer or an officer of the permanent mission of a Contracting State in the other Contracting State or in a third State, shall for the purposes of the Convention be deemed a resident of the sending State if:
- (a) Under international law, his income from sources outside the receiving State or capital situated outside that State is not taxed therein;
- (b) His total income or property is taxed in the sending State in the same way as that of a resident of that State.
(4) The Convention shall not apply to international organizations, their organs or officials, nor to diplomatic agents, consular officers or the officers of the permanent mission of a third State, who are present in a Contracting State, but whose income or capital is not taxed in either Contracting State in the same way as that of residents of that State.