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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.


Members of Diplomatic Missions and Consular Posts

(1) The provisions of this Convention shall not affect the tax privileges granted to members of diplomatic missions and consular posts under the general rules of international law or under the provisions of special agreements.

(2) Where income or property is not taxed in the receiving State on the basis of the fiscal privileges granted to diplomatic missions and consular posts in accordance with the general rules of international law or because of special international agreements, the assigning State shall be entitled to tax such income and property.

(3) Notwithstanding the provisions of Article 4, an individual who is a member of a diplomatic mission, of a consular post, or of a permanent representation of a Contracting State located in another Contracting State or in a third-party State shall be deemed to be a resident of the assigning State for the purposes of this Convention as long as such person is:

  • (a) in accordance with international law, not subject to tax in the receiving State for income from sources outside of this State or for property situated outside of this State, and;
  • (b) in the assigning State, subject to the same tax obligations in respect of his or her entire income or property as residents of this State.

(4) This Convention shall not apply to international organizations, their executives or officials, and to members of a diplomatic mission or consular post of a third State and their members who are present in a Contracting State and who are not subject in either of the two Contracting States to the same obligations in terms of taxes on income or property as residents of such Contracting State.