{"id":469,"date":"2025-10-01T03:22:26","date_gmt":"2025-10-01T03:22:26","guid":{"rendered":"https:\/\/whimsical-pyramid.localsite.io\/?p=469"},"modified":"2025-10-01T03:22:26","modified_gmt":"2025-10-01T03:22:26","slug":"sudan","status":"publish","type":"post","link":"https:\/\/investinasia.id\/education\/tax-treaty\/sudan\/","title":{"rendered":"Sudan"},"content":{"rendered":"
\n
\n

AGREEMENT BETWEEN
\n THE GOVERNMENT OF THE REPUBLIC OF INDONESIA
\n AND
\n THE GOVERNMENT OF THE REPUBLIC OF SUDAN<\/b><\/p>\n

FOR<\/span>
\n THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL
\n EVASION WITH RESPECT TO TAXES ON INCOME<\/b>\n <\/p>\n

Article 1
\n PERSONAL SCOPE<\/b><\/p>\n

This Agreement shall apply to
\n persons
\n who are residents of one or both of the Contracting States.<\/p>\n

Article 2
\n TAXES COVERED<\/b><\/p>\n

    \n
  1. \n

    This Agreement shall apply to
    \n taxes
    \n on income imposed on behalf of each Contracting State or of its
    \n political subdivisions or local authorities, irrespective of the manner
    \n in which they are levied. <\/p>\n<\/li>\n

  2. \n

    There shall be regarded as taxes
    \n on
    \n income all taxes imposed on total income, or on elements of income,
    \n including taxes on gains from the alienation of movable or immovable
    \n property. <\/p>\n<\/li>\n

  3. \n

    The existing taxes to which the
    \n Agreement shall apply are: \n <\/p>\n\n\n\n\n\n\n\n
    (a)<\/td>\nin Indonesia:
    \n the income tax imposed under the Undang-undang Pajak Penghasilan 1984
    \n (Law Number 7 of 1983 as amended);
    \n (hereinafter referred to as “Indonesian tax”);<\/td>\n<\/tr>\n
    (b)<\/td>\nin the Republic of Sudan:<\/td>\n<\/tr>\n
    (i)<\/td>\nthe
    \n income tax;<\/td>\n<\/tr>\n
    (ii)<\/td>\nthe
    \n capital gains tax;<\/td>\n<\/tr>\n
    (hereinafter
    \n referred to as “Sudan tax”).<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

    \n<\/li>\n

  4. \n

    The Agreement shall apply also
    \n to
    \n any identical or substantially similar taxes which are imposed after
    \n the date of signature of the Agreement in addition to, or in place of,
    \n the existing taxes. The competent authorities of the Contracting States
    \n shall notify each other of any substantial changes which have been made
    \n in their respective taxation laws. <\/p>\n<\/li>\n<\/ol>\n

    Article 3
    \n GENERAL DEFINITION<\/b><\/p>\n

      \n
    1. \n

      For the purposes of this
      \n Agreement, unless the context otherwise requires;\n <\/p>\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n
      (a)<\/td>\n(i)<\/td>\nthe
      \n term “Indonesia” means the territory of the Republic of Indonesia as
      \n defined in its laws;\n <\/td>\n<\/tr>\n
      (ii)<\/td>\nthe term
      \n “Sudan” means the territory of the Republic of Sudan as defined in its
      \n laws; <\/td>\n<\/tr>\n
      (b)<\/td>\nthe term
      \n “company” means any body corporate or any entity which is treated as a
      \n body corporate for tax purposes;<\/td>\n<\/tr>\n
      (c)<\/td>\nthe term
      \n “person” includes an individual, a company and any other body of
      \n persons;<\/td>\n<\/tr>\n
      (d)<\/td>\nthe terms
      \n “enterprise of a Contracting State” and “enterprise of the other
      \n Contracting State” mean respectively an enterprise carried on by a
      \n resident of [a] Contracting State and an enterprise carried on by a
      \n resident of the other Contracting State;<\/td>\n<\/tr>\n
      (e)<\/td>\nthe term
      \n “international traffic” means any transport by a ship or aircraft
      \n operated by an enterprise of a Contracting State, except when the ship
      \n or aircraft is operated solely between places in the other Contracting
      \n State;<\/td>\n<\/tr>\n
      (f)<\/td>\nthe term
      \n “competent authority” means:<\/td>\n<\/tr>\n
      (i)<\/td>\nin Indonesia:
      \n the Minister of Finance or his authorized representative;
      \n <\/span> <\/td>\n<\/tr>\n
      (ii)<\/td>\nin the case of the
      \n Sudan:<\/span>
      \n the Mini<\/span>ster of
      \n Finance or his authorized representative;<\/td>\n<\/tr>\n
      (g)<\/td>\nthe term “national” means:<\/td>\n<\/tr>\n
      (i)\n <\/td>\nany individual possessing the nationality
      \n of a
      \n Contracting State; \n <\/td>\n<\/tr>\n
      (ii)<\/td>\nany legal person, partnership and
      \n association
      \n deriving its status as such from the laws in force in a Contracting
      \n State.<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

      \n<\/li>\n

    2. \n

      As regards the application of
      \n the
      \n Agreement by a Contracting State any term not defined therein shall,
      \n unless the context otherwise requires, have the meaning which it has
      \n under the laws of that State concerning the taxes to which the
      \n Agreement applies. <\/p>\n<\/li>\n<\/ol>\n

      Article 4
      \n RESIDENT<\/b><\/p>\n

        \n
      1. \n

        For the purpose of this
        \n Agreement,
        \n the term “resident of a Contracting State” means any person who, under
        \n the laws of that State, is liable to tax therein by reason of his
        \n domicile, residence, place of management or any other criterion of a
        \n similar nature. <\/p>\n<\/li>\n

      2. \n

        Where by reason of the
        \n provisions
        \n of paragraph
        \n 1 an individual is a resident of both Contracting States, then his
        \n status shall be determined as follows:\n <\/p>\n\n\n\n\n\n
        (a)<\/td>\n\n

        he shall be deemed to be a resident of
        \n the State in which he has a permanent home available to him; if he has
        \n a permanent home available to him in both States, he shall be deemed to
        \n be a resident of the State with which his personal and economic
        \n relations are closer (center of vital interests);<\/p>\n<\/td>\n<\/tr>\n

        (b)<\/td>\n\n

        if the State in which he has his center
        \n of vital interests cannot be determined, or if he has not a permanent
        \n home available to him in either State, he shall be deemed to be a
        \n resident of the State in which he has an habitual abode;<\/p>\n<\/td>\n<\/tr>\n

        (c)<\/td>\n\n

        if he has an habitual abode in both
        \n States or in neither of them, the competent authorities of the
        \n Contracting States shall settle the question by mutual agreement.<\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

        \n<\/li>\n

      3. \n

        Where, by reason of paragraph 1
        \n a
        \n person other
        \n than an individual is a resident of both Contracting States, the
        \n competent authorities of the States, then it shall be deemed to be a
        \n resident of the State in which its place of effective management is
        \n situated.<\/p>\n<\/li>\n<\/ol>\n

        Article 5
        \n PERMANENT ESTABLISHMENT<\/b><\/p>\n

          \n
        1. \n

          For the purposes of this
          \n Agreement,
          \n the term “permanent establishment” means a fixed place of business
          \n through which the business of an enterprise of a Contracting State in
          \n wholly or partly carried on in the other Contracting State. <\/p>\n<\/li>\n

        2. \n

          The term “permanent
          \n establishment”
          \n includes especially:\n <\/p>\n\n\n\n\n\n\n\n\n\n\n
          (a)<\/td>\na place of management;<\/td>\n<\/tr>\n
          (b)<\/td>\na
          \n branch;<\/td>\n<\/tr>\n
          (c)<\/td>\nan
          \n office;<\/td>\n<\/tr>\n
          (d)<\/td>\na
          \n factory;<\/td>\n<\/tr>\n
          (e)<\/td>\na
          \n workshop;<\/td>\n<\/tr>\n
          (f)<\/td>\na
          \n warehouse or premises used as sales outlet;<\/td>\n<\/tr>\n
          (g)<\/td>\na
          \n farm or plantation;<\/td>\n<\/tr>\n
          (h)<\/td>\n\n

          a mine, an oil of gas well, a quarry or
          \n other place of extraction or exploration or exploitation of natural
          \n resources, drilling rig or working ship.<\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

          \n<\/li>\n

        3. \n

          The term “permanent
          \n establishment”
          \n likewise encompasses: <\/p>\n\n\n\n\n
          (a)\n <\/td>\na
          \n building site, a construction, assembly or installation project or
          \n supervisory activities in connection therewith, but only where such
          \n site, project or activities continue for a period of more than 6
          \n months; <\/td>\n<\/tr>\n
          (b)\n <\/td>\nthe
          \n furnishing of services, including consultancy services by an enterprise
          \n through employees or other personnel engaged by the enterprise for such
          \n purpose, but only where activities of that nature continue (for the
          \n same or a connected project) within the country for a period or periods
          \n aggregating more than 3 months within any twelve-month period. <\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n<\/li>\n
        4. \n

          Notwithstanding the preceding
          \n provisions of this Article, the term “permanent establishment” shall be
          \n deemed not to include: \n <\/p>\n\n\n\n\n\n\n\n\n\n
          (a)<\/td>\n\n

          the use of facilities solely for the
          \n purpose of
          \n storage or display of goods or merchandise belonging to the
          \n enterprise; <\/p>\n<\/td>\n<\/tr>\n

          (b)<\/td>\n\n

          the maintenance of a stock of goods or
          \n merchandise
          \n belonging to the enterprise solely for the purpose of storage or
          \n display;<\/p>\n<\/td>\n<\/tr>\n

          (c)<\/td>\n\n

          the maintenance of a stock of goods or
          \n merchandise
          \n belonging to the enterprise solely for the purpose of processing by
          \n another enterprise;<\/p>\n<\/td>\n<\/tr>\n

          (d)<\/td>\n\n

          the maintenance of a fixed place of
          \n business solely
          \n for the purpose of purchasing goods or merchandise or of collecting
          \n information, for the enterprise; <\/p>\n<\/td>\n<\/tr>\n

          (e)<\/td>\n\n

          the maintenance of a fixed place of
          \n business solely
          \n for the purpose of advertising, or for the supply of
          \n information; <\/p>\n<\/td>\n<\/tr>\n

          (f)<\/td>\n\n

          the maintenance of a fixed place of
          \n business solely
          \n for the purpose of carrying on, for the enterprise, any other activity
          \n of a preparatory or auxiliary character; <\/p>\n<\/td>\n<\/tr>\n

          (g)<\/td>\n\n

          the maintenance of a fixed place of
          \n business solely
          \n for any combination of activities mentioned in sub-paragraphs (a) to
          \n (f), provided that the overall activity of the fixed place of business
          \n resulting from this combination is of a preparatory or auxiliary
          \n character. <\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

          \n<\/li>\n

        5. \n

          Notwithstanding the provisions
          \n of
          \n paragraphs 1 and 2, where a person — other than an agent of an
          \n independent status to whom paragraph 6 applies — is acting in a
          \n Contracting State on behalf of an enterprise of the other Contracting
          \n State, that enterprise shall be deemed to have a permanent
          \n establishment in the first-mentioned State in respect of any activities
          \n which that person undertakes for the enterprise, if such a
          \n person: \n <\/p>\n\n\n\n\n\n
          (a)<\/td>\n\n

          has or habitually exercises in that
          \n State an
          \n authority to conclude contracts in the name of the enterprise, unless
          \n the activities of such person are limited to those mentioned in
          \n paragraph 4 which, if exercised through a fixed place of business,
          \n would not make this fixed place of business a permanent establishment
          \n under the provisions of that paragraph; or <\/p>\n<\/td>\n<\/tr>\n

          (b)<\/td>\n\n

          has no such authority, but habitually
          \n maintains in
          \n the first-mentioned State a stock of goods or merchandise from which he
          \n regularly delivers goods or merchandise on behalf of the enterprise;
          \n or <\/p>\n<\/td>\n<\/tr>\n

          (c)<\/td>\n\n

          manufactures or processes in that State
          \n for the
          \n enterprise goods or merchandise belonging to the enterprise. <\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

          \n<\/li>\n

        6. \n

          Notwithstanding the preceding
          \n provisions of this Article, an insurance enterprise of a Contracting
          \n State shall, except in regard to re-insurance, be deemed to have a
          \n permanent establishment in the other Contracting State if it collects
          \n premiums in the territory of that other State or insures risks situated
          \n therein through a person other than an agent of an independent status
          \n to whom paragraph 7 applies. <\/p>\n<\/li>\n

        7. \n

          An enterprise of a Contracting
          \n State shall not be deemed to have a permanent establishment in the
          \n other Contracting State merely because it carries on business in that
          \n other State through a broker, general commission agent or any other
          \n agent of an independent status, provided that such persons are acting
          \n in the ordinary course of their business. However, when the activities
          \n of such an agent are devoted wholly or almost wholly on behalf of that
          \n enterprise, he will not be considered an agent of an independent status
          \n within the meaning of this paragraph.<\/p>\n<\/li>\n

        8. \n

          The fact that a company which
          \n is a
          \n resident of a Contracting State controls or is controlled by a company
          \n which is a resident of the other Contracting State, or which carries on
          \n business in that other State (whether through a permanent establishment
          \n or otherwise), shall not of itself constitute either company a
          \n permanent establishment of the other.<\/p>\n<\/li>\n<\/ol>\n

          Article 6
          \n INCOME FROM IMMOVABLE PROPERTY<\/b><\/p>\n

            \n
          1. \n

            Income derived by a resident of
            \n a
            \n Contracting State from immovable property (including income from
            \n agriculture or forestry) situated in the other Contracting State may be
            \n taxed in that other State. <\/p>\n<\/li>\n

          2. \n

            The term “immovable property”
            \n shall
            \n have the meaning which it has under the law of the Contracting State in
            \n which the property in question is situated. The term shall in any case
            \n include property accessory to immovable property, livestock and
            \n equipment used in agriculture and forestry, rights to which the
            \n provisions of general law respecting landed property apply, usufruct of
            \n immovable property and rights to variable or fixed payments as
            \n consideration for the working of, or the right to work, mineral
            \n deposits, sources and other natural resources. Ships and aircraft shall
            \n not be regarded as immovable property.<\/p>\n<\/li>\n

          3. \n

            The provisions of paragraph 1
            \n shall
            \n also apply to income derived from the direct use, letting, or use in
            \n any other form of immovable property. <\/p>\n<\/li>\n

          4. \n

            The provisions of paragraphs 1
            \n and
            \n 3 shall also apply to the income from immovable property of an
            \n enterprise and to income from immovable property used for the
            \n performance of independent personal services. <\/p>\n<\/li>\n<\/ol>\n

            Article 7
            \n BUSINESS PROFITS<\/b><\/p>\n

              \n
            1. \n

              The profits of an enterprise of
              \n a
              \n Contracting State shall be taxable only in that State unless the
              \n enterprise carries on business in the other Contracting State through a
              \n permanent establishment situated therein. If the enterprise carries on
              \n business as aforesaid, the profits of the enterprise may be taxed in
              \n the other State but only so much of them as is attributable
              \n to: <\/p>\n\n\n\n\n\n
              (a)<\/td>\n\n that permanent establishment;<\/td>\n<\/tr>\n
              (b)<\/td>\n\n sales in that other State of
              \n goods or merchandise of the same or similar kind as those sold through
              \n that permanent establishment; or<\/td>\n<\/tr>\n
              (c)<\/td>\n\n other business activities carried
              \n on in that other State of the same or similar kind as those effected
              \n through that permanent establishment.<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n<\/li>\n
            2. \n

              Subject to the provisions of
              \n paragraph 3, where an enterprise of a Contracting State carries on
              \n business in the other Contracting State through a permanent
              \n establishment situated therein, there shall in each Contracting State
              \n be attributed to that permanent establishment the profits which it
              \n might be expected to make if it were a distinct and separate enterprise
              \n engaged in the same or similar activities under the same or similar
              \n conditions and dealing wholly independently with the enterprise of
              \n which it is a permanent establishment. <\/p>\n<\/li>\n

            3. \n

              In determining the profits of a
              \n permanent establishment, there shall be allowed as deductions expenses
              \n which are incurred for the purposes of the business of the permanent
              \n establishment including executive and general administrative expenses
              \n so incurred, whether in the State in which the permanent establishment
              \n is situated or elsewhere. However, no such deduction shall be allowed
              \n in respect of amounts, if any, paid (otherwise than towards
              \n reimbursement of actual expenses) by the permanent establishment to the
              \n head office of the enterprise or any of its other offices, by way of
              \n royalties, fees or other similar payments in return for the use of
              \n patents or other rights, or by way of commission, for specific services
              \n performed or for management, or, except in the case of a banking
              \n enterprise, by way of interest on moneys lent to the permanent
              \n establishment. Likewise, no account shall be taken, in the
              \n determination of the profits of a permanent establishment, for amounts
              \n charged, (otherwise than towards reimbursement of actual expenses), by
              \n the permanent establishment to the head office of the enterprise or any
              \n of its other offices, by way of royalties, fees or other similar
              \n payments in return for the use of patents or other rights, or by way of
              \n commission for specific services performed or for management, or,
              \n except in the case of a banking enterprise, by way of interest on
              \n moneys lent to the head office of the enterprise or any of its other
              \n offices. <\/p>\n<\/li>\n

            4. \n

              For the purposes of the
              \n preceding
              \n paragraphs, the profits to be attributed to the permanent establishment
              \n shall be determined by the same method year by year unless there is
              \n good and sufficient reason to the contrary. <\/p>\n<\/li>\n

            5. \n

              Where profits include items of
              \n income which are dealt with separately in other Articles of this
              \n Agreement, then the provisions of those Articles shall not be affected
              \n by the provisions of this Article.<\/p>\n<\/li>\n<\/ol>\n

              Article 8
              \n SHIPPING AND AIR TRANSPORT<\/b><\/p>\n

                \n
              1. \n

                Profits derived by an enterprise
                \n of
                \n a Contracting State from the operation of [a] ship or aircraft in
                \n international traffic shall be taxable only in that Contracting State.<\/p>\n<\/li>\n

              2. \n

                The provisions of paragraphs 1
                \n and
                \n 2 shall also apply to profits from the participation in a pool, a joint
                \n business or an international operating agency. <\/p>\n<\/li>\n<\/ol>\n

                Article 9
                \n ASSOCIATED ENTERPRISES<\/b><\/p>\n

                  \n
                1. \n

                  Where:<\/p>\n\n\n\n\n
                  (a)<\/td>\n\n an enterprise of a Contracting
                  \n State participates directly or indirectly in the management, control or
                  \n capital of an enterprise of the other Contracting State, or<\/td>\n<\/tr>\n
                  (b)<\/td>\n\n the same persons participate
                  \n directly or indirectly in the management, control or capital of an
                  \n enterprise of a Contracting State and an enterprise of the other
                  \n Contracting State,<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n
                  \n

                  and in either case conditions
                  \n are
                  \n made or imposed between the two enterprises in their commercial or
                  \n financial relations which differ from those which would be made between
                  \n independent enterprises, then any profits which would, but for those
                  \n conditions, have accrued to one of the enterprises, but, by reason of
                  \n those conditions, have not so accrued, may be included in the profits
                  \n of that enterprises and taxed accordingly.<\/p>\n<\/p><\/div>\n<\/li>\n

                2. \n
                  \n

                  Where a Contracting State
                  \n includes
                  \n in the profits of an enterprise of that State — and taxes accordingly
                  \n — profits on which an enterprise of the other Contracting State has
                  \n been charged to tax in that other State and the profits so included are
                  \n profits which would have accrued to the enterprise of the
                  \n first-mentioned State if the conditions made between the two
                  \n enterprises had been those which would have been made between
                  \n independent enterprises, then that other State shall make an
                  \n appropriate adjustment to the amount of the tax charged therein on
                  \n those profits. In determining such adjustment, due regard shall be had
                  \n to the other provisions of the Agreement and the competent authorities
                  \n of the Contracting States shall, if necessary consult each other.<\/p>\n<\/p><\/div>\n<\/li>\n

                3. \n

                  A Contracting State shall not
                  \n change the profits of an enterprise in the circumstances referred to in
                  \n paragraph 2 after the expiry of the time limits provided in its tax
                  \n laws. <\/p>\n<\/li>\n<\/ol>\n

                  Article 10
                  \n DIVIDENDS<\/b><\/p>\n

                    \n
                  1. \n

                    Dividends paid by a company
                    \n which
                    \n is a resident of a Contracting State to a resident of the other
                    \n Contracting State may be taxed in that other State. <\/p>\n<\/li>\n

                  2. \n

                    However, if the beneficial owner
                    \n of
                    \n the dividends is a resident of the other Contracting State, the tax
                    \n charged by the first-mentioned State may not exceed 10 per cent of the
                    \n gross amount of the dividends actually distributed.<\/p>\n<\/li>\n

                  3. \n

                    The term “dividends” as used in
                    \n this Article means income from shares or other rights, not being
                    \n debt-claims, participating in profits, as well as income from other
                    \n corporate rights which is subjected to the same taxation treatment as
                    \n income from shares by the laws of the State of which the company making
                    \n the distribution is a resident.<\/p>\n<\/li>\n

                  4. \n

                    The provisions of paragraphs 1
                    \n and
                    \n 2 shall not apply if the beneficial owner of the dividends, being a
                    \n resident of a Contracting State, carries on business in the other
                    \n Contracting State of which the company paying the dividends is a
                    \n resident, through a permanent establishment situated therein, or
                    \n performs in that other State independent personal services from a fixed
                    \n base situated therein, and the holding in respect of which the
                    \n dividends are paid is effectively connected with such permanent
                    \n establishment or fixed base. In such case, the provisions of Article 7
                    \n or Article 14, as the case may be, shall apply. <\/p>\n<\/li>\n

                  5. \n

                    Notwithstanding any other
                    \n provisions of this Agreement where a company which is a resident of a
                    \n Contracting State has a permanent establishment in the other
                    \n Contracting State, the profits of the permanent establishment may be
                    \n subjected to an additional tax in that other State in accordance with
                    \n its law, but the additional tax so charged shall not exceed 10 per cent
                    \n of the amount of such profits after deducting therefrom income tax and
                    \n other taxes on income imposed thereon in that other State. <\/p>\n<\/li>\n

                  6. \n

                    The provision of paragraph 5 of
                    \n this Article shall not affect the provision contained in any production
                    \n sharing contract and relating to [the] oil and gas sector concluded by
                    \n the Government of Indonesia, its instrumentality, its relevant state
                    \n oil and gas company or any other entity thereof with a person who is a
                    \n resident of the other Contracting States.<\/p>\n<\/li>\n<\/ol>\n

                    Article 11
                    \n INTEREST<\/b><\/p>\n

                      \n
                    1. \n

                      Interest arising in a
                      \n Contracting
                      \n State and paid to a resident of the other Contracting State may be
                      \n taxed in that other Contracting State if such resident is the
                      \n beneficial owner of the interest. <\/p>\n<\/li>\n

                    2. \n

                      The rate of tax imposed by one
                      \n of
                      \n Contracting States on interest derived from sources within that
                      \n Contracting State and beneficially owned by resident of the other
                      \n Contracting State shall not exceed 15 per cent of the gross amount of
                      \n the interest. <\/p>\n<\/li>\n

                    3. \n

                      Notwithstanding the provisions
                      \n of
                      \n paragraph 2, interest arising in a Contracting State and derived by the
                      \n Government of the other Contracting State including local authorities
                      \n thereof, a political subdivision, the Central Bank or any financial
                      \n institution controlled by that Government, the capital of which is
                      \n wholly owned by the Government of the other Contracting State, as may
                      \n be agreed upon from time to time between the competent authorities of
                      \n the Contracting States, shall be exempt from tax in the first-mentioned
                      \n State.<\/p>\n<\/li>\n

                    4. \n

                      The term “interest” as used in
                      \n this
                      \n Article means income from debt-claims of every kind, whether or not
                      \n secured by mortgage, and whether or not carrying a right to participate
                      \n in the debtor’s profits, and in particular, income from government
                      \n securities and income from bonds or debentures, including premiums and
                      \n prizes attaching to such securities, bonds or debentures, as well as
                      \n income assimilated to income from money lent under the taxation law of
                      \n the States in which the income arises, including interest on deferred
                      \n payment sales. <\/p>\n<\/li>\n

                    5. \n

                      The provisions of paragraphs 1
                      \n and
                      \n 2 shall not apply if the beneficial owner of the interest, being a
                      \n resident of a Contracting State, carries on business in the other
                      \n Contracting State in which the interest arises, through a permanent
                      \n establishment situated therein, or performs in that other State
                      \n independent personal services from a fixed base situated therein, and
                      \n the debt-claim in respect of which the interest is paid is effectively
                      \n connected with (a) such permanent establishment or fixed base, or with
                      \n (b) business activities referred to under (c) of paragraph 1 of Article
                      \n 7. In such case, the provisions of Article 7 or 14, as the case may be,
                      \n shall apply.<\/p>\n<\/li>\n

                    6. \n

                      Interest shall be deemed to
                      \n arise
                      \n in a Contracting State when the payer is that State itself, a political
                      \n subdivision, a local authority or a resident of that State. Where,
                      \n however, the person paying the interest, whether he is a resident of a
                      \n Contracting State or not, has in a Contracting State a permanent
                      \n establishment or a fixed base in connection with which the indebtedness
                      \n on which the interest is paid was incurred, and such interest is borne
                      \n by such permanent establishment or fixed base, then such interest shall
                      \n be deemed to arise in the State in which the permanent establishment or
                      \n fixed base is situated. <\/p>\n<\/li>\n

                    7. \n

                      Where by reason of a special
                      \n relationship between the payer and the beneficial owner or between both
                      \n of them and some other person, the amount of the interest, having
                      \n regard to the debt-claim for which it is paid, exceeds the amount which
                      \n would have been agreed upon by the payer and the beneficial owner in
                      \n the absence of such relationship, the provisions of this Article shall
                      \n apply only to the last-mentioned amount. In such case, the excess part
                      \n of the payments shall remain taxable according to the laws of each
                      \n Contracting State, due regard being had to the other provisions of this
                      \n Agreement. <\/p>\n<\/li>\n<\/ol>\n

                      Article 12
                      \n ROYALTIES<\/b><\/p>\n

                        \n
                      1. \n

                        Royalties arising in a
                        \n Contracting
                        \n State and paid to a resident of the other Contracting State may be
                        \n taxed in that other State. <\/p>\n<\/li>\n

                      2. \n

                        The rate of tax imposed by one
                        \n of
                        \n [the] Contracting States on royalties derived from sources within that
                        \n Contracting State and beneficially owned by [a] resident of the other
                        \n Contracting State shall not exceed 10 per cent of the gross amount of
                        \n the royalties described in paragraph 3. <\/p>\n<\/li>\n

                      3. \n

                        The term “royalties” as used in
                        \n this Article means payments, whether periodical or not, and in whatever
                        \n form or name or nomenclature to the extent to which they are made as
                        \n consideration for: \n <\/p>\n\n\n\n\n\n\n\n\n\n\n
                        (a)<\/td>\n\n

                        the use of, or the right
                        \n to
                        \n use, any copyright, patent, design or model, plan, secret formula or
                        \n process, trademark or other like property or right; or <\/p>\n<\/td>\n<\/tr>\n

                        (b)<\/td>\n\n

                        the use of, or the right
                        \n to
                        \n use, any industrial, commercial or scientific equipment; or <\/p>\n<\/td>\n<\/tr>\n

                        (c)<\/td>\n\n

                        the supply of
                        \n scientific,
                        \n technical, industrial or commercial knowledge or information;
                        \n or <\/p>\n<\/td>\n<\/tr>\n

                        (d)<\/td>\n\n

                        the supply of any
                        \n assistance
                        \n that is ancillary and subsidiary to any such property or right as is
                        \n mentioned in sub-paragraph (a), any such equipment as is mentioned in
                        \n sub-paragraph (b) or any such knowledge or information as is mentioned
                        \n in sub-paragraph (c); or<\/p>\n<\/td>\n<\/tr>\n

                        (e)<\/td>\n\n

                        the use of, or the right
                        \n to
                        \n use:<\/p>\n<\/td>\n<\/tr>\n

                        (i)<\/td>\n\n

                        motion picture films;
                        \n or<\/p>\n<\/td>\n<\/tr>\n

                        (ii)<\/td>\n\n

                        films or video for use
                        \n in
                        \n connection with television; or<\/p>\n<\/td>\n<\/tr>\n

                        (iii)<\/td>\n\n

                        tapes for use in
                        \n connection
                        \n with radio broadcasting; or<\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

                        \n<\/li>\n

                      4. \n

                        The provisions of paragraphs 1
                        \n and
                        \n 2 shall not apply if the beneficial owner of the royalties, being a
                        \n resident of a Contracting State, carries on business in the other
                        \n Contracting State in which the royalties arise, through a permanent
                        \n establishment situated therein, or performs in that other State
                        \n independent personal services from a fixed base situated therein, and
                        \n the right or property in respect of which the royalties are paid is
                        \n effectively connected with (a) such permanent establishment or fixed
                        \n base, or with (b) business activities referred to under (c) of
                        \n paragraph 1 of Article 7. In such case, the provisions of Article 7 or
                        \n Article 14, as the case may be, shall apply. <\/p>\n<\/li>\n

                      5. \n

                        Royalties shall be deemed to
                        \n arise
                        \n in a Contracting State when the payer is that State itself, a local
                        \n authority or a resident of that State. Where, however, the person
                        \n paying the royalties, whether he is a resident of a Contracting State
                        \n or not, has in a Contracting State a permanent establishment or a fixed
                        \n base in connection with which the liability to pay the royalties was
                        \n incurred, and such royalties are borne by such permanent establishment
                        \n or fixed base, then such royalties shall be deemed to arise in the
                        \n State in which the permanent establishment or fixed base is
                        \n situated. <\/p>\n<\/li>\n

                      6. \n

                        Where, by reason of a special
                        \n relationship between the payer and the beneficial owner or between both
                        \n of them and some other person, the amount of the royalties, having
                        \n regard to the use, right or information for which they are paid,
                        \n exceeds the amount which would have been agreed upon by the payer and
                        \n the beneficial owner in the absence of such relationship, the
                        \n provisions of this Article shall apply only to the last-mentioned
                        \n amount. In such case, the excess part of the payment shall remain
                        \n taxable according to the laws of each Contracting State, due regard
                        \n being had to the other provisions of this Agreement. <\/p>\n<\/li>\n<\/ol>\n

                        Article 13
                        \n CAPITAL GAINS<\/b><\/p>\n

                          \n
                        1. \n

                          Gains derived by a resident of a
                          \n Contracting State from the alienation of immovable property referred to
                          \n in Article 6 and situated in the other Contracting State may be taxed
                          \n in that other State.<\/p>\n<\/li>\n

                        2. \n

                          Gains from the alienation of
                          \n movable property forming part of the business property of a permanent
                          \n establishment which an enterprise of a Contracting State has in the
                          \n other Contracting State or of movable property pertaining to a fixed
                          \n base available to a resident of a Contracting State in the other
                          \n Contracting State for the purpose of performing independent personal
                          \n services, including such gains from the alienation of such a permanent
                          \n establishment (alone or with the whole enterprise) or of such fixed
                          \n base, may be taxed in that other State. <\/p>\n<\/li>\n

                        3. \n

                          Gains derived by an enterprise
                          \n of a
                          \n Contracting State from the alienation of ships or aircraft operated in
                          \n international traffic or movable property pertaining to the operation
                          \n of such ships or aircraft shall be taxable only in that State. <\/p>\n<\/li>\n

                        4. \n

                          Gains from the alienation of any
                          \n property other than that referred to in the preceding paragraphs shall
                          \n be taxable only in the Contracting State of which the alienator is a
                          \n resident. <\/p>\n<\/li>\n<\/ol>\n

                          Article 14
                          \n INDEPENDENT PERSONAL SERVICES<\/b><\/p>\n

                            \n
                          1. \n

                            Income derived by a resident of
                            \n a
                            \n Contracting State in respect of professional services or other
                            \n activities of an independent character shall be taxable only in that
                            \n State unless he has a fixed base regularly available to him in the
                            \n other Contracting State for the purpose of performing his activities or
                            \n he is present in that other State for a period or periods exceeding in
                            \n the aggregate 90 days within any twelve-month period. If he has such a
                            \n fixed base or remains in that other State for the aforesaid period or
                            \n periods, the income may be taxed in that other State but only so much
                            \n of it as is attributable to that fixed base or is derived in that other
                            \n State during the aforesaid period or periods.<\/p>\n<\/li>\n

                          2. \n

                            The term “professional services”
                            \n includes especially independent scientific, literary, artistic,
                            \n educational or teaching activities as well as the independent
                            \n activities of physicians, engineers, lawyers, dentists, architects, and
                            \n accountants. <\/p>\n<\/li>\n<\/ol>\n

                            Article 15
                            \n DEPENDENT PERSONAL SERVICES<\/b><\/p>\n

                              \n
                            1. \n

                              Subject to the provisions of
                              \n Articles 16, 18, 19 and 20, salaries, wages and other similar
                              \n remuneration derived by a resident of a Contracting State in respect of
                              \n an employment shall be taxable only in that State unless the employment
                              \n is exercised in the other Contracting State. If the employment is so
                              \n exercised, such remuneration as is derived therefrom may be taxed in
                              \n that other State.<\/p>\n<\/li>\n

                            2. \n

                              Notwithstanding the provisions
                              \n of
                              \n paragraph 1, remuneration derived by a resident of a Contracting State
                              \n in respect of an employment exercised in the other Contracting State
                              \n shall be taxable only in the first-mentioned State, if: \n <\/p>\n\n\n\n\n\n
                              (a)<\/td>\n\n

                              the recipient is present in that other
                              \n State for a
                              \n period or periods not exceeding in the aggregate 183 days within any
                              \n twelve-month period; and <\/p>\n<\/td>\n<\/tr>\n

                              (b)<\/td>\n\n

                              the remuneration is paid by, or on
                              \n behalf of, an
                              \n employer who is not a resident of that other State; and <\/p>\n<\/td>\n<\/tr>\n

                              (c)<\/td>\n\n

                              the remuneration is not borne by a
                              \n permanent
                              \n establishment or a fixed base which the employer has in the other
                              \n State. <\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

                              \n<\/li>\n

                            3. \n

                              Notwithstanding the preceding
                              \n provisions of this Article, remuneration derived in respect of an
                              \n employment exercised aboard a ship or aircraft operated in
                              \n international traffic by an enterprise of a Contracting State shall be
                              \n taxable only in that State. <\/p>\n<\/li>\n<\/ol>\n

                              Article 16
                              \n DIRECTORS’ FEES<\/b><\/p>\n

                                \n
                              1. \n

                                Directors’ fees and other
                                \n similar
                                \n payments derived by a resident of a Contracting State in his capacity
                                \n as a member of the board of directors or any other similar organ of a
                                \n company which is a resident of the other Contracting State may be taxed
                                \n in that other State. <\/p>\n<\/li>\n

                              2. \n

                                The remuneration which a person
                                \n to
                                \n whom paragraph 1 applies derived from the company in respect of the
                                \n discharge of day-to-day functions of a managerial or technical nature
                                \n may be taxed in accordance with the provisions of Article 15. <\/p>\n<\/li>\n<\/ol>\n

                                Article 17
                                \n ARTISTES AND ATHLETES<\/b><\/p>\n

                                  \n
                                1. \n

                                  Notwithstanding the provisions
                                  \n of
                                  \n Articles 14 and 15, income derived by a resident of a Contracting State
                                  \n as an entertainer, such as a theatre, motion picture, radio or
                                  \n television artiste, or a musician, or as an athlete, from his personal
                                  \n activities as such exercised in the other Contracting State, may be
                                  \n taxed in that other State. <\/p>\n<\/li>\n

                                2. \n

                                  Where income in respect of
                                  \n personal
                                  \n activities exercised by an entertainer or an athlete in his capacity as
                                  \n such accrues not to the entertainer or athlete himself but to another
                                  \n person, that income may, notwithstanding the provisions of Articles 7,
                                  \n 14 and 15, be taxed in the Contracting State in which the activities of
                                  \n the entertainer or athlete are exercised. <\/p>\n<\/li>\n

                                3. \n

                                  Notwithstanding the provisions
                                  \n of
                                  \n paragraphs 1 and 2, income derived from activities referred to in
                                  \n paragraph 1 performed under a cultural agreement or arrangement between
                                  \n the Contracting States shall be exempt from tax in the Contracting
                                  \n State in which the activities are exercised if the visit to that State
                                  \n is wholly or substantially supported by funds of one or both of the
                                  \n Contracting States, a local authority or public institution
                                  \n thereof. <\/p>\n<\/li>\n<\/ol>\n

                                  Article 18
                                  \n PENSIONS AND ANNUITIES<\/b><\/p>\n

                                    \n
                                  1. \n

                                    Subject to the provisions of
                                    \n paragraphs 2 of Article 19, any pensions or other similar remuneration
                                    \n paid to a resident of one of the Contracting States from a source in
                                    \n the other Contracting State in consideration of past employment or
                                    \n services in that other Contracting State and any annuity paid to such a
                                    \n resident from such a source may be taxed in that other State. <\/p>\n<\/li>\n

                                  2. \n

                                    The term “annuity” means a
                                    \n stated
                                    \n sum payable periodically at stated times during life or during a
                                    \n specified or ascertainable period of time under an obligation to make
                                    \n the payments in return for adequate and full consideration in money or
                                    \n money’s worth. <\/p>\n<\/li>\n<\/ol>\n

                                    Article 19
                                    \n GOVERNMENT SERVICE<\/b><\/p>\n\n\n\n\n\n\n\n\n\n
                                    1.<\/td>\n(a)<\/td>\n\n

                                    Remuneration, other than a
                                    \n pension, paid by a Contracting State, or a political subdivision, or a
                                    \n local authority thereof to an individual in respect of services
                                    \n rendered to that State or subdivision or authority shall be taxable
                                    \n only in that State.<\/p>\n<\/td>\n<\/tr>\n

                                    (b)<\/td>\n\n

                                    However, such remuneration
                                    \n shall
                                    \n be taxable only in the other Contracting State if the services are
                                    \n rendered in that other State and the individual is a resident of that
                                    \n State who:<\/p>\n<\/td>\n<\/tr>\n

                                    (i)<\/td>\n\n

                                    is a national of that
                                    \n state; or<\/p>\n<\/td>\n<\/tr>\n

                                    (ii)<\/td>\n\n

                                    did not become a resident of
                                    \n that
                                    \n State solely for the purpose of rendering the services. <\/p>\n<\/td>\n<\/tr>\n

                                    2.<\/td>\n(a)<\/td>\n\n

                                    Any pension paid by, or out
                                    \n of
                                    \n funds created by, a Contracting State or a political subdivision or a
                                    \n local authority thereof to an individual in respect of services
                                    \n rendered to that State or subdivision or authority shall be taxable
                                    \n only in that State.<\/p>\n<\/td>\n<\/tr>\n

                                    (b)<\/td>\n\n

                                    However, such pension shall
                                    \n be
                                    \n taxable only in the other Contracting State if the individual is a
                                    \n resident of, and a national of, that other State.<\/p>\n<\/td>\n<\/tr>\n

                                    \n 3.<\/td>\n\n

                                    The provisions of Articles
                                    \n 15, 16
                                    \n and 18 shall apply to remunerations and pensions in respect of services
                                    \n rendered in connection with a business carried on by a Contracting
                                    \n State or a political subdivision or a local authority thereof.<\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

                                    Article 20
                                    \n TEACHERS AND RESEARCHERS<\/b><\/p>\n

                                    An
                                    \n individual who is immediately before visiting a Contracting State a
                                    \n resident of the other Contracting State and who, at the invitation of
                                    \n the Government of the first-mentioned Contracting State or of a
                                    \n University, college, school, museum or other cultural institution in
                                    \n that first-mentioned Contracting State or under an official programme
                                    \n of cultural exchange, is present in that Contracting State for a period
                                    \n not exceeding two consecutive years solely for the purpose of teaching,
                                    \n giving lectures or carrying out research at such institution shall be
                                    \n exempt from tax in that Contracting State on his remuneration for such
                                    \n activity.<\/div>\n

                                    Article 21
                                    \n STUDENTS AND TRAINEES<\/b><\/p>\n

                                      \n
                                    1. \n

                                      Payments which a student or
                                      \n business trainee who is or was immediately before visiting a
                                      \n Contracting State a resident of the other Contracting State and who is
                                      \n present in the first-mentioned Contracting State solely for the purpose
                                      \n of his education or training received for the purpose of his
                                      \n maintenance, education or training shall not be taxed in that
                                      \n Contracting State, provided that such payments arise from sources
                                      \n outside that Contracting State. <\/p>\n<\/li>\n

                                    2. \n

                                      In respect of grants,
                                      \n scholarships,
                                      \n and remuneration from employment not covered by paragraph 1, a student
                                      \n or business trainee described in paragraph 1 shall, in addition, be
                                      \n entitled during such education or training to the same exemption,
                                      \n reliefs or reductions in respect of taxes available to residents of the
                                      \n Contracting State which he is visiting. <\/p>\n<\/li>\n<\/ol>\n

                                      Article 22
                                      \n OTHER INCOME<\/b><\/p>\n

                                      Items
                                      \n of income of a resident of a Contracting State, wherever arising, not
                                      \n dealt with on the foregoing Articles of this Agreement, other than
                                      \n income in the form of lotteries [or] prizes shall be taxable in that
                                      \n State.<\/div>\n

                                      Article 23
                                      \n METHOD FOR ELIMINATION OF DOUBLE TAXATION<\/b><\/p>\n

                                      Where
                                      \n a resident of a Contracting State derives income from the other
                                      \n Contracting State, the amount of tax on that income payable in that
                                      \n other Contracting State in accordance with the provisions of this
                                      \n Agreement, may be credited against the tax levied in the
                                      \n first-mentioned Contracting State imposed on that resident. The amount
                                      \n of credit, however, shall not exceed the amount of the tax on the
                                      \n first-mentioned Contracting State on that income computed in accordance
                                      \n with its taxation laws and regulations.<\/div>\n

                                      Article 24
                                      \n NON-DISCRIMINATION<\/b><\/p>\n

                                        \n
                                      1. \n

                                        Nationals of a Contracting State
                                        \n shall not be subjected in the other Contracting State to any taxation
                                        \n or any requirement connected therewith which is other or more
                                        \n burdensome than the taxation and connected requirements to which
                                        \n nationals of that other State in the same circumstances are or may be
                                        \n subjected. <\/p>\n<\/li>\n

                                      2. \n

                                        The taxation on a permanent
                                        \n establishment which an enterprise of a Contracting State has in the
                                        \n other Contracting State shall not be less favourably levied in that
                                        \n other State than the taxation levied on enterprises of that other State
                                        \n carrying on the same activities. This provision shall not be construed
                                        \n as obliging a Contracting State to grant to residents of the other
                                        \n Contracting State any personal allowances, reliefs and reductions for
                                        \n taxation purposes on account of civil status or family responsibilities
                                        \n which it grants to its own residents. <\/p>\n<\/li>\n

                                      3. \n

                                        Enterprises of a Contracting
                                        \n State,
                                        \n the capital of which is wholly or partly owned or controlled, directly
                                        \n or indirectly, by one or more residents of the other Contracting State,
                                        \n shall not be subjected in the first-mentioned State to any taxation or
                                        \n any requirement connected therewith which is other or more burdensome
                                        \n than the taxation and connected requirements to which other similar
                                        \n enterprises of the first-mentioned State are or may be subjected.<\/p>\n<\/li>\n

                                      4. \n

                                        Except where the provisions of
                                        \n paragraph 1 of Article 9, paragraph 7 of Article 11, or paragraph 6 of
                                        \n Article 12 apply, interest, royalty [sic] and other disbursements paid
                                        \n by an enterprise of a Contracting State to a resident of the other
                                        \n Contracting State shall, for the purpose of determining the taxable
                                        \n profits of such enterprise, be deductible under the same conditions as
                                        \n if they had been paid to a resident of the first-mentioned
                                        \n State. <\/p>\n<\/li>\n

                                      5. \n

                                        In this Article the term
                                        \n “taxation”
                                        \n means taxes which are the subject of this Agreement. <\/p>\n<\/li>\n<\/ol>\n

                                        Article 25
                                        \n MUTUAL AGREEMENT PROCEDURE<\/b><\/p>\n

                                          \n
                                        1. \n

                                          Where a person considers that
                                          \n the
                                          \n actions of one or both of the Contracting States result or will result
                                          \n for him in taxation not in accordance with the provisions of this
                                          \n Agreement, he may, irrespective of the remedies provided by the
                                          \n domestic law of those States, present his case to the competent
                                          \n authority of the Contracting State of which he is a resident or, if his
                                          \n case comes under paragraph 1 of Article 24, to that of the Contracting
                                          \n State of which he is a national. The case must be presented within two
                                          \n years from the first notification of the action resulting in taxation
                                          \n not in accordance with the provisions of the Agreement.<\/p>\n<\/li>\n

                                        2. \n

                                          The competent authority shall
                                          \n endeavour, if the objection appears to it to be justified and if it is
                                          \n not itself able to arrive at a satisfactory solution, to resolve the
                                          \n case by mutual agreement with the competent authority of the other
                                          \n Contracting State, with a view to the avoidance of taxation which is
                                          \n not in accordance with this Agreement. <\/p>\n<\/li>\n

                                        3. \n

                                          The competent authorities of the
                                          \n Contracting States shall endeavour to resolve by mutual agreement any
                                          \n difficulties or doubts arising as to the interpretation or application
                                          \n of the Agreement. They may also consult together for the elimination of
                                          \n double taxation in cases not provided for in the Agreement. <\/p>\n<\/li>\n

                                        4. \n

                                          The competent authorities of the
                                          \n Contracting States may communicate with each other directly for the
                                          \n purpose of reaching an agreement in the sense of the preceding
                                          \n paragraphs. The competent authorities, through consultations, shall
                                          \n develop appropriate bilateral procedures, conditions, methods and
                                          \n techniques for the implementation of the mutual agreement procedure
                                          \n provided for in this Article. <\/p>\n<\/li>\n<\/ol>\n

                                          Article 26
                                          \n EXCHANGE OF INFORMATION<\/b><\/p>\n

                                            \n
                                          1. \n

                                            The competent authorities of the
                                            \n Contracting States shall exchange such information as is necessary for
                                            \n carrying out the provisions of this Agreement or of the domestic laws
                                            \n of the Contracting States concerning taxes covered by the Agreement,
                                            \n insofar as the taxation thereunder is not contrary to this Agreement,
                                            \n in particular for the prevention of fraud or evasion of such taxes. The
                                            \n exchange of information is not restricted by Article 1. Any information
                                            \n received by a Contracting State shall be treated as secret in the same
                                            \n manner as information obtained under the domestic laws of that State.
                                            \n However, if the information is originally regarded as secret in the
                                            \n transmitting State it shall be disclosed only to persons or authorities
                                            \n (including courts and administrative bodies) involved in the assessment
                                            \n or collection of, the enforcement or prosecution in respect of, or the
                                            \n determination of appeals in relation to, the taxes which are the
                                            \n subject of the Agreement. Such persons or authorities shall
                                            \n use the information only for such purposes but may disclose the
                                            \n information in public court proceedings, or in judicial decisions.<\/p>\n<\/li>\n

                                          2. \n

                                            In no case shall the provisions
                                            \n of
                                            \n paragraph 1 be construed so as to impose on a Contracting State the
                                            \n obligation:\n <\/p>\n\n\n\n\n\n
                                            (a)<\/td>\n\n

                                            to carry out administrative measures at
                                            \n variance
                                            \n with the laws and administrative practice of that or of the other
                                            \n Contracting State; <\/p>\n<\/td>\n<\/tr>\n

                                            (b)<\/td>\n\n

                                            to supply information which is not
                                            \n obtainable under
                                            \n the laws or in the normal course of the administration of that or of
                                            \n the other Contracting State;<\/p>\n<\/td>\n<\/tr>\n

                                            (c)<\/td>\n\n

                                            to supply information which would
                                            \n disclose any
                                            \n trade, business, industrial, commercial or professional secret or trade
                                            \n process, or information, the disclosure of which would be contrary to
                                            \n public policy (ordre public). <\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

                                            \n<\/li>\n<\/ol>\n

                                            Article 27
                                            \n DIPLOMATIC AGENTS AND CONSULAR OFFICERS<\/b><\/p>\n

                                            Nothing
                                            \n in this Agreement shall affect the fiscal privileges of diplomatic
                                            \n agents or consular officers under the general rules of international
                                            \n law or under the provisions of special agreements.<\/div>\n

                                            Article 28
                                            \n ENTRY INTO FORCE<\/b><\/p>\n

                                              \n
                                            1. \n

                                              This Agreement shall enter into<\/p>\n

                                              force on the later of the dates on which the respective Governments may
                                              \n notify each other in writing that the formalities constitutionally
                                              \n required in their respective States have been complied with. <\/p>\n<\/li>\n

                                            2. \n

                                              This Agreement shall have
                                              \n effect:\n <\/p>\n\n\n\n\n
                                              (a)<\/td>\n\n

                                              in respect of tax withheld at the source
                                              \n to income
                                              \n derived on or after 1 January in the year next following that in which
                                              \n the Agreement enters into force; and <\/p>\n<\/td>\n<\/tr>\n

                                              (b)<\/td>\n\n

                                              in respect of other taxes on income, for
                                              \n taxable
                                              \n years beginning on or after 1 January in the year next following that
                                              \n in which the Agreement enters into force.<\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

                                              \n<\/li>\n<\/ol>\n

                                              Article 29
                                              \n TERMINATION<\/b><\/p>\n

                                              This
                                              \n Agreement shall remain in force until terminated by a Contracting
                                              \n State. Either Contracting State may terminate the Agreement, through
                                              \n diplomatic channels, by giving written notice of termination on or
                                              \n before the thirtieth day of June of any calendar year following after
                                              \n the period of 5 years from the year in which the Agreement enters into
                                              \n force.<\/div>\n

                                              In such case, the Agreement shall
                                              \n cease
                                              \n to have effect:<\/p>\n\n\n\n\n
                                              (a)<\/td>\n\n

                                              in respect of tax withheld
                                              \n at
                                              \n source to income derived on or after 1 January in the year next
                                              \n following that in which the notice of termination is given;<\/p>\n<\/td>\n<\/tr>\n

                                              (b)<\/td>\n\n

                                              in respect of other taxes
                                              \n on
                                              \n income, for
                                              \n taxable years beginning on or after 1 January in the year next
                                              \n following that in which the notice of termination is given.<\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

                                              <\/p>\n

                                              In
                                              \n witness whereof the undersigned, duly authorized thereto by their
                                              \n respective governments, have signed this Agreement.<\/div>\n
                                               <\/div>\n
                                              \n
                                              Done in duplicate at
                                              \n Khartoum this 10th day of February 1998 in the English, Indonesian and
                                              \n Arabic languages. All texts being equally authentic. In case of any
                                              \n divergent interpretation of the Indonesian and Arabic text, the English
                                              \n text shall prevail.\n <\/div>\n

                                              \n <\/div>\n\n\n\n
                                              \n

                                              FOR THE GOVERNMENT OF
                                              \n THE REPUBLIC OF INDONESIA
                                              \n Signed
                                              \n SOEMADI D.M. BROTODININGRAT<\/p>\n<\/td>\n

                                              		\n

                                              FOR THE GOVERNMENT OF
                                              \n THE REPUBLIC OF SUDAN
                                              \n Signed
                                              \n ABDUL GADIR MUHAMMAD AHMED<\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table><\/div>\n<\/p><\/div>\n","protected":false},"excerpt":{"rendered":"

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