ARTICLE 27
Members of Diplomatic Missions and Consular Posts
(1) Nothing in this Convention shall affect the fiscal privileges of members of diplomatic missions or consular posts under the general rules of international law or under the provisions of special agreements.
(2) Insofar as, due to the fiscal privileges granted to the members of diplomatic missions or consular posts under the general rules of international law or under the provisions of special international agreements, items of income or elements of capital are not subject to tax, the sending State shall have the right to tax.
(3) Notwithstanding the provisions of Article 4, an individual who is a member of a diplomatic mission, a consular post or a permanent mission of a Contracting State which is situated in the other Contracting State or in a third state shall be deemed for the purposes of the Convention to be a resident of the sending State if:
- (a) in accordance with international law he is not liable to tax in the receiving State in respect of items of income from sources outside that State; and
- (b) he is liable in the sending State to the same obligations in relation to tax on his total income or capital as are residents of that State.
(4) This Convention shall not apply to international organizations, to organs or officials thereof, and to members of a diplomatic mission or consular post of a third State, being present in a Contracting State but not being treated in either Contracting State for purposes of taxes on income and on capital as residents are treated.