- 1
- The benefits of this Convention are not applicable to companies or other persons which are wholly or partly exempted from tax by a special regime under the laws of either one of the Contracting States. They are also not applicable to income from such companies or other persons derived by a resident of the other State, nor to shares, “jouissance” rights or interests in such companies or other persons. The provisions of this paragraph are also applicable to any identical or substantially similar legislation in addition to or replacing such a special regime enacted after this Convention enters into force unless the competent authorities of the States decide otherwise by mutual agreement.
- 2
- The provisions of paragraph 1 of this Article are also applicable in case a company or other person is treated under the administrative practice of that State in the same or similar way as a company or person as meant in that paragraph.
- 3
- Notwithstanding the provisions of paragraphs 1 and 2 of this Article, the competent authorities of the States shall by mutual agreement decide which special regime is meant in the provisions of paragraph 1 of this Article.
