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.
ARTICLE 28
Members of Diplomatic Missions and Consular Posts
(1) This Convention shall not affect the fiscal privileges that members of diplomatic missions and consular posts are entitled to according to the general practices of international law or under the provisions of special understandings.
(2) Notwithstanding the provisions of Article 4, an individual who is a member of a diplomatic mission, a consular post or a permanent delegate of one Contracting State, and is located in the other Contracting State or in a third State, is to be considered as a resident of the State whose delegate he is, if he:
- (a) in accordance with the international law, he is not subject to tax in the Receiver-State, for income from sources outside this State or has property situated outside this State, and
- (b) is subjected, in the Sending-State, to the same obligations with respect to the tax from his total income or from property as residents of this State are subjected to.