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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.


Diplomatic and Consular Officers

(1) The provisions of this Convention shall not affect the fiscal privileges of diplomatic agents and consular officers under the general rules of international law or under the provisions of special agreements.

(2) Insofar as the income or property of a person is not taxed in the receiving State by reason of the privileges corresponding under general rules of international law or under the provisions of special international agreements, the right to tax shall correspond to the sending State.

(3) In the application of this Convention, members of a diplomatic mission or consular office of a Contracting State, situated in the other Contracting State or in a third State, as well as the persons living with them, shall be deemed to be residents of the sending State, when they possess the nationality thereof and are subject to taxation of income and capital therein, as residents of that State.

(4) This Convention shall not apply to members of diplomatic missions of consular offices in a third State, who, while living in one of the Contracting States, are not however deemed to be residents of either of the Contracting States for purposes of income and capital purposes.