However, those royalties may also be taxed in the Contracting State in which they arise, and according to the law of that State, but the tax so charged shall not exceed 5 per cent. The rate of tax imposed in the country of source on royalties beneficially owned by a resident of the other country is not to exceed 5 per cent. Pensions including government pensions and annuities paid to a resident of a Contracting State shall be taxable only in that State. However, if such income arises in the other country, it may also be taxed in that country Article 20. Other income not specified in the Convention will generally be taxed only by the country of which the beneficial owner is a resident. However, that interest may also be taxed in the Contracting State in which it arises, and according to the law of that State, but the tax so charged shall not exceed 10 per cent. Pensions including government pensions and annuities are to be taxed only in the country of residence of the recipient Article 17. Where profits include items of income or gains which are dealt with separately in other Articles of this Convention, then the provisions of those Articles shall not be affected by the provisions of this Article.

Income from real property and income or gains from the alienation of real property may be taxed in the country in which the property is situated Articles 6 and 13. Ships and aircraft shall not be regarded as real property. This Convention shall apply to persons who are residents of one or both of the Contracting States. The situation of interests or rights referred to in paragraph 2 of Article 6 shall be determined for the purposes of this Article in accordance with paragraph 3 of Article 6. Income derived by a resident of a Contracting State from real property may be taxed in the Contracting State in which the real property is situated. The first line just sets up the geographic qualification. Members of a partnership may be taxed in their country of residence on their individual shares of the income or gains of the partnership, even if the partnership is treated as a taxable unit under the law of the other country Article 24. But only the report's fine print spelled out that long haul flights and people not travelling on the cheapest fares would be hit much harder.

In general, where income continues to be taxable in both countries, credit is to be given by the country of the taxpayer's residence for tax imposed by the other country Article 22. Royalties arising in a Contracting State and beneficially owned by a resident of the other Contracting State may be taxed in that other State. The discussion above is general in nature and may not apply to all individuals. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise. Subject to certain specified exceptions, each country may tax capital gains in accordance with its domestic law Article 13. Profits from international shipping and air transport and income or gains from the alienation of ships or aircraft operated internationally are generally to be taxed only in the residence state of the enterprise Articles 8 and 13. Dividends paid by a company which is a resident of a Contracting State for the purposes of its tax, being dividends beneficially owned by a resident of the other Contracting State, may be taxed in that other State. This one comes up often enough that we need an FAQ. The provisions of paragraph 1 of this Article shall apply to income derived from the direct use, letting, or use in any other form of real property.