1. Any pension, with another pension within the meaning of Article 19, or any annuity from a contracting state from sources within the other contracting state, is taxable only in the first contracting state. 4. Notwithstanding the provisions of this article, the term “permanent establishment” is deemed not to be included: 6. Where profits are subject to income that is treated separately in other sections of this agreement, the provisions of this article are not affected by the provisions of this section. 4. Notwithstanding the provisions of this article, the existing taxes to which the Convention applies also include, in the case of France, inheritance tax, but only for the application of Articles 4, 23, 25 and 26. (4) Capital represented by shares or other rights (other than shares or other rights covered in paragraph 2) that are part of a vital interest in a corporation that is established in a contracting state may be taxed in that state. A core interest is considered to be such when a related individual or person directly or indirectly holds shares or other rights whose total amount gives at least 25 per cent of the company`s profits. 4. The term “aircraft operation” refers to the transportation of passengers, mail, livestock or goods carried by aircraft owners or charterers, including the sale of air tickets for this transport on behalf of other companies, the occasional rental of aircraft and any other activity directly related to that transportation. 7. Where a company established in a contracting state derives profits or income from the other contracting state, that other contracting state may not collect tax on the dividends paid by the corporation, unless those dividends are paid to a country in that other State party or the shareholding for which the dividends are paid is effectively linked to a stable institution or a fixed base.
in that other contracting state, do not subject the company`s untributed profits to a tax on the company`s un distributed profits, even if the dividends paid or untributed profits are made up, in whole or in part, of profits or income earned in that other contracting state. (6) Interest is considered in a contracting state to be those where the payer is the contracting state itself, a political sub-division, a territorial authority or a resident of that contracting state. However, if the person who pays the interest, whether or not he is domiciled in a contracting state, has a stable establishment or a fixed base on which the fault on which the interest is paid was born, and if that interest is borne by that stable institution or by a fixed base, those interests apply in the contracting state where the stable establishment or fixed base is located. 2. The competent authority endeavours to resolve the matter by mutual agreement with the competent authority of the other contracting State where the objection appears to be well founded and is unable to find an appropriate solution to resolve the matter by mutual agreement with the competent authority of the other contracting State, in order to avoid taxation that is not in accordance with the convention.