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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.

ARTICLE 3

INCOME SUBJECT TO TAX

(1) The following categories of income derived from sources within one Contracting State by a resident of the other Contracting State shall be subject to tax only in that other Contracting State:

  • (a) rentals, royalties, or other amounts paid as consideration for the use of or right to use literary, artistic, and scientific works, or for the use of copyrights of such works, as well as the rights to inventions (patents, author's certificates), industrial designs, processes or formulae, computer programs, trademarks, service marks, and other similar property or rights, or for industrial, commercial, or scientific equipment, or for knowledge, experience, or skill (know-how);
  • (b) gains derived from the sale or exchange of any such rights or property, whether or not the amounts realized on sale or exchange are contingent in whole or in part, on the extent and nature of use or disposition of such rights or property;
  • (c) gains from sale or other disposition of property received as a result of inheritance or gift;
  • (d) income from the furnishing of engineering, architectural, designing, and other technical services in connection with an installment contract with a resident of the first Contracting State which are carried out in a period not exceeding 36 months at one location;
  • (e) income from the sale of goods or the supplying of services through a broker, general commission agent or other agent of independent status, where such broker, general commission agent or other agent is acting in the ordinary course of his business;
  • (f) reinsurance premiums; and
  • (g) interest on credits, loans and other forms of indebtedness connected with the financing of trade between the USA and the USSR except where received by a resident of the other Contracting State from the conduct of a general banking business in the first Contracting State.

(2) A Contracting State shall not attribute taxable income to the following activities conducted within that Contracting State by a resident of the other Contracting State:

  • (a) the purchase of goods or merchandise;
  • (b) the use of facilities for the purpose of storage or delivery of goods or merchandise belonging to the resident of the other Contracting State;
  • (c) the display of goods or merchandise belonging to the resident of the other Contracting State, and also the sale of such items on termination of their display;
  • (d) advertising by a resident of the other Contracting State, the collection or dissemination of information, or the conducting of scientific research, or similar activities, which have a preparatory or auxiliary character for the resident.