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Law No. 25 Of 12 March 1992 On The Ratification Of The Agreement Between The Government Of Romania And The Government Of The Hellenic Republic For The Avoidance Of Double Taxation With Respect To Taxes On Income And Wealth

Original Language Title:  LEGE nr. 25 din 12 martie 1992 privind ratificarea Convenţiei dintre Guvernul României şi Guvernul Republicii Elene pentru evitarea dublei impuneri cu privire la impozitele pe venit şi pe avere

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LEGE No. 25 of March 12, 1992 on the ratification of the Convention between the Government of Romania and the Government of the Hellenic Republic to avoid double taxation on income and wealth taxes
ISSUER PARLIAMENT
Published in OFFICIAL MONITOR NO. 46 of 20 March 1992



The Convention between the Government of Romania and the Government of the Hellenic Republic for the avoidance of double taxation on income and wealth taxes, signed in Athens on 17 September 1991, is ratified. + Annex 1 + Article 1 Romanian Government and Government of the Hellenic Republic in the desire to promote and strengthen economic relations between the two countries on the basis of national sovereignty and respect for independence, equality in rights, mutual benefit and non-interference in domestic affairs, have agreed on those who follows: Data subjects This Convention shall apply to persons resident of one or both Contracting States. + Article 2 Targeted taxes 1. The present convention shall apply to income and wealth taxes established by a contracting state, its administrative-territorial units or local authorities, regardless of how they are perceived. 2. They are considered income and wealth taxes all taxes established on total income, on total wealth or on income or wealth items including taxes on gains from the disposal of movable or immovable property, as well as taxes on increasing the value of wealth. 3. The existing taxes to which this Convention will apply shall be in particular: a) In case of Romania: (I) the income tax obtained by individuals; (II) payroll tax and other similar remuneration; (III) corporate income tax; (IV) income tax made by individuals from agricultural activities (hereinafter referred to as Romanian tax); b) For the Hellenic Republic: (I) the income and wealth tax of natural persons; (II) the tax on income and wealth of legal entities; (III) the contribution for the Water Delivery and Drenation Agency, calculated on the total income from buildings (hereinafter referred to as Greek tax); 4. This Convention shall also apply to any identical or substantially similar taxes, which shall be determined after the date of signature of this Convention and which shall be added or replaced by existing taxes. At the end of each year, the competent authorities of the Contracting States shall notify each other of any substantial changes to their respective tax laws. + Article 3 General definitions 1. For the purposes of this Convention, unless the context requires otherwise: a) the term Romania means Romania and, used in geographical sense, designates the territory of Romania, including its territorial sea, as well as the exclusive economic zone and the continental shelf in respect of which Romania exercises, in accordance with the right international and its own legislation, sovereign rights concerning the exploration and exploitation of existing natural, biological and mineral resources in the waters of the sea, on the bottom and in its basement; b) the term "Hellenic Republic" means the territory of the Hellenic Republic and the part of the seafloor and its sub-soil in the Mediterranean over which the Hellenic Republic has c) the term person includes a natural person, a company, and any other entity of persons; d) the term of the Company means any legal person, including a joint venture constituted in accordance with the provisions of the legislation of the Contracting State, or any entity that is considered as a legal person for the purpose of taxation e) the terms of the undertaking of a contracting and undertaking State of the other Contracting State shall indicate, respectively, an undertaking operated by a resident of a Contracting State and an undertaking operated by a resident of the other State contractor; f) the terms of a contracting state and the other contracting state means Romania or the Hellenic Republic, as the context requires; g) the term international traffic means any transport carried out by an aircraft operated by an undertaking which has its place of effective management in a Contracting State or a vessel which has its place of registration or the documents of registration in a Contracting State unless the ship or aircraft operates only between two places located in the other Contracting State; h) the term competent authority means: (I) in the case of Romania, Minister of Economy and Finance or his authorized representative; ((II) In the case of the Hellenic Republic, the Minister of Finance or his authorized 2. Regarding the application of this Convention by a Contracting State any term that is not otherwise defined will have if the context does not otherwise require the meaning it has within the legislation of that State with respect to the taxes to which This Convention shall apply. + Article 4 1. For the purposes of this Convention, the term resident of a Contracting State shall designate any person who, by virtue of the legal provisions of that State, is the subject of taxation in this State, due to his domicile, his residency, the seat management or by virtue of any other criterion of a similar nature. This term does not include those persons who are subject to taxation in this state only for income from sources in that state or wealth located within it. 2. When, according to the provisions of paragraph 1, a natural person is a resident of both contracting states, then his tax status will be solved as follows: a) the person will be considered resident of the contracting state in which he has a permanent home at his disposal; if he has a permanent home at his disposal in both contracting states, she will be considered a resident of the contracting state with which his personal and economic ties are the most extinguished (the center of vital interests); b) if the contracting state in which this person has the centre of his vital interests cannot be determined or if this person does not have a permanent home at his disposal in any of the contracting states, then it will be considered residence of the contracting state in which he habitually resides; c) if this person habitually resides in both Contracting States or does not habitually reside in any of them, she shall be considered a resident of the Contracting State whose national is; d) if this person is a national of both contracting states or is not national of any of them, the competent authorities of the contracting states will resolve the matter by mutual agreement. 3. When, according to the provisions of paragraph 1 a person, other than a natural person, is a resident of both contracting states, then he will be considered to be a resident of the contracting state in which the place of his effective management is located. + Article 5 Permanent establishment 1.For the purposes of this Convention, the expression of permanent establishment shall indicate a fixed place of business whereby the undertaking exercises in full or in part its business. . The permanent establishment shall include in particular: a) a driving seat; b) a branch; c) an office; d) a plant; e) a workshop; f) a mine, a well, oil or gas extraction, a career or any other place of exploitation or exploration of natural resources. 3. A construction or assembly site or a installation project shall constitute a permanent establishment only if its duration is more than 9 months. 4. Independent of the previous provisions of this article, the expression of permanent establishment shall be deemed not to include: a) the use of installations only for the purpose of storage, exposure or delivery of goods or goods belonging to the enterprise; b) maintaining a stock of products or goods belonging to the enterprise, only in order to be stored, exposed or delivered; c) the maintenance of a stock of goods or goods belonging to the undertaking solely for the purpose of processing by another undertaking; d) maintaining a stable place of business only in order to buy products or goods or to gather information for the enterprise; e) maintaining a stable place of business only for the purpose of carrying out for the enterprise any other activity of a preparer or auxiliary character f) maintaining a fixed place of business only for the purpose of carrying out combined activities in the category of those mentioned in subparagraphs a)-e), provided that the entire activity of the fixed business place resulting from this combination has a Auxiliary character or preparer. g) products or goods belonging to the undertaking and are displayed in a tirade or occasional temporary exhibition which shall be sold during the circulation and shall be delivered immediately after their closure. 5 5. Independent of the provisions of paragraph 1 and 2, when a person-other than an agent with independent status, to whom paragraph 7 applies-acts on behalf of an enterprise and has as usual activity in the contracting state to conclude contracts on behalf of the undertaking, that undertaking shall be deemed to have a permanent establishment in that State in respect of any activities which that person carries out for the undertaking, unless the activities of that undertaking persons are limited to those referred to in paragraph 4 which, if exercised by a fixed place of business, does not make this place fixed by business a permanent establishment under the conditions of that paragraph. 6. A person whose activity is related to the exploitation or exploration of the seabed or its subsoil as well as natural resources located in a contracting state will be considered to carry out a business activity through a headquarters Permanent in that state. 7. An undertaking shall not be deemed to have a permanent establishment in a Contracting State through a broker, a general commission agent or any other independent status agent, provided that such persons act within the framework of the their usual activity. 8. The fact that a resident company of a Contracting State controls or is controlled by a company that is resident of the other Contracting State or which exercises its activity in the other Contracting State (either through a permanent establishment or otherwise) is not by itself sufficient to make one of these companies a permanent establishment of the other. + Article 6 Income from real estate 1. The income obtained by a resident of a contracting state from immovable property (including from agriculture or forestry) located in the other contracting state may be imposed in that state. 2. The expression of immovable property is defined in accordance with the legislation of the contracting state in which the goods in question are located. The expression will include in any case, the accessories of real estate, the living and dead inventory of agricultural and forestry holdings, the rights to which the common law on land property, the use of immovable property and the rights to variable or fixed rents for the exploitation or concession of the exploitation of mineral deposits, sources and other natural resources of the soil; vessels, vessels and aircraft shall not be regarded as immovable property. 3. The provisions of paragraph 1 shall apply to income obtained from direct use, rental or use in any other form of real estate. 4. The provisions of paragraphs 1 and 3 will also apply to income from real estate of an enterprise and income from immovable property used for the conduct of a personal service provision activity. independent. + Article 7 Business benefits 1. The benefits of an undertaking of a Contracting State shall be taxable only in that State, unless the undertaking exercises its activity in the other Contracting State through a permanent establishment situated in that State. If the undertaking exercises an activity, as previously mentioned, the benefits of the undertaking may be imposed in the other Contracting State, but only that part which can be attributed to that permanent establishment. 2. Subject to the provisions of paragraph 3, when an enterprise of a contracting state carries out activity in the other contracting state through a permanent establishment located in that state, then it shall be awarded in each contracting state to that permanent establishment of the benefits it could have achieved if it constituted a separate and separate undertaking by exercising identical or analogous activities, under identical or analogous conditions and dealing with all independence with the undertaking of the whose permanent establishment is. 3. Upon determining the benefit of a permanent establishment will be granted as decreases the expenses made for the purposes pursued by the permanent establishment, including driving expenses and general administration expenses regardless of the fact that they carried out in the Contracting State or elsewhere. 4. To the extent that in a Contracting State it is customary that the benefits of assigned to a permanent establishment be determined by apportioning the total benefits of the undertaking between its various component parts, no provision of the paragraph 2 does not prevent that contracting state from determining, as is usual, the benefits to be imposed on the basis of such distribution; however, the method of distribution adopted will be in such a way that the result consorts with the principles contained in this Article. 5. No benefit shall be assigned to a permanent establishment only for the fact that that permanent establishment buys products or goods for the enterprise. 6. For the purposes of the preceding paragraphs, the benefits to be assigned to the permanent establishment will be determined each year by the same method, unless there are sufficient and valid reasons to proceed otherwise. 7. When the benefits include income elements that are treated separately in articles of this Convention, the provisions of those articles shall not be affected by the provisions of this article. + Article 8 1. The benefits obtained from the exploitation of ships in international traffic will be taxable only in the contracting state in which the ships are registered or for which they have documents. 2. The benefits obtained from the exploitation of aircraft in international traffic will be taxable only in the contracting state in which the place of the actual management of the enterprise is located. 3. The provisions of paragraph 2 will also apply to benefits obtained from participation in a pool, to a joint operation or to an international transport agency. + Article 9 Associated enterprises When: a) an undertaking of a Contracting State shall participate directly or indirectly in the management, control or capital of an undertaking of the other Contracting State, or b) the same persons participate directly or indirectly in the management, control or capital of an undertaking of a Contracting State and an undertaking of the other Contracting State, And, in any of these two situations, conditions are established or imposed between the two undertakings in their commercial or financial relations, which differ from those which would be established between independent undertakings, then any benefits which, if it would not have been these conditions, it would have been obtained but, due to those conditions could not be obtained, they can be included in the benefits of that enterprise and imposed accordingly. + Article 10 Dividends 1. The dividends paid by a resident company of a Contracting State to a resident person of the other Contracting State may be imposed in that State. 2. However, such dividends may also be imposed in the contracting state in which the dividend paying company is resident, according to the legislation of that state, but if the one that collects them is the beneficial owner of the dividends, the tax thus determined shall not exceed: a) 45 percent of the gross amount of dividends, if the company that distributes them is a resident of Greece, and b) 25 percent of the gross amount of dividends, if the company that distributes them is a resident of Romania. The competent authorities of the Contracting States shall agree on how to apply these limitations. This paragraph will not affect the company's taxation for the benefits from which the dividends are paid. 3. The term dividends, as used in this article, means income coming from shares, shares or securities, mining parties parts of founder or other rights, except receivables, which participate in the realization. benefits, as well as income from other social parts that are subject to the same taxation regime as income from shares by the tax legislation of the contracting state in which the dividend distribution company is resident. 4. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the dividends, being a resident of a contracting state carries out income-producing activities in the other contracting state in which the dividend-paying company is resident, through a permanent establishment located in that State or carries out in that State independent services, using a fixed base located there, and the stake held, in relation to which the dividends are paid, is effectively related to this permanent establishment or fixed base. In such cases, the provisions of art. 7 7 or art. 15 15, as appropriate. 5. When a resident company of a Contracting State carries out benefits or income from the other Contracting State, that Contracting State may not levy any tax on dividends paid by the Company, except where such dividends are paid to a resident of that State or to the extent that the stake in relation to which the dividends are paid are effectively linked to a permanent establishment or a fixed base located in that State, nor to take any tax on the undistributed benefits of the company, even if dividends paid or benefits undistributed represents in whole or in part, benefits or income coming from that contracting state. + Article 11 Dobinzi 1. The Dobindays coming from a Contracting State and paid to a resident of the other Contracting State may be imposed in that Contracting State. 2. However, such interests may also be imposed in the contracting state from which they come and in accordance with the legislation of that state but, if the recipient is the beneficial owner of the interests, the tax thus established will not exceed 10 percent of the gross amount of interest. The competent authorities of the Contracting States shall agree on how to apply this limitation. 3. The term interest, as used in this Article, means income from debt securities of any kind guaranteed or not mortgage and whether or not they give the right; to participate in the benefits of the debtor and, in particular, income from public effects and income from bonds, including premiums and awards arising from these public effects or bonds. Penalties for late payment shall not be considered as interest for the purposes of this Article. 4. The provisions of paragraphs 1 and 2 will not apply if the beneficial owner of the resident interests of a contracting state, carries out income-producing activities in the other contracting state in which the interest is born through a headquarters permanently located there or perform in the other contracting state personal services with an independent character using a fixed base located there and if the debt securities with respect to which the interest is paid are effectively related to such of permanent establishment or fixed base. In such cases, the provisions of art. 7 7 or art. 15 15 as appropriate. 5. Interest will be considered to be born in a contracting state when the debtor is that contracting state, an administrative-territorial unit, a local authority or a resident of that state. When, however, the paying person of the interests, whether or not he is a resident of a contracting state, has in a contracting state a permanent establishment or a fixed base in relation to which the claim on which the interest is paid and these interest are borne by that permanent establishment or fixed base, then these interest will be considered to be born in the state where the permanent establishment or fixed base is located. 6. When, due to the special relations existing between the debtor and the beneficial owner or between both and another person, the amount of the interest, taking into account the claim for which they are paid exceeds the amount on which the debtor and the beneficial owner in the absence of such relations, the provisions of this Article shall apply only to that latter amount. In this case, the excess part of the payments will remain taxable according to the legislation of each contracting state, taking into account the other provisions of this Convention. + Article 12 Commissions 1. Commissions coming from a contracting state and paid to a resident of the other contracting state, may be imposed in that state. 2. However, such commissions may be imposed in the contracting state from which they come and in accordance with the legislation of that State, but the tax thus established shall not exceed 5 percent of the amount of the commission. The competent authorities of the Contracting States shall agree on how to apply this limitation. 3. The term commissions as used in this article, means a payment made to an intermediary, to a general commission agent or to any other person assimilated to such an intermediary or agent, by the tax law of the state contractor from which such payment originates. 4. The provisions of paragraphs 1 and 2 will not apply if the beneficiary of the commission, resident of a contracting state, has in the other contracting state from which the commission comes a permanent establishment to which the activity generating commission. In such case, the provisions of art. 7. 5. The commissions will be considered to be born in a contracting state when the debtor is even that state, an administrative-territorial unit, a local authority or a resident of that state. When, however, the paying person of the commissions, whether or not he is a resident of a contracting state, has in a contracting state a permanent establishment that is linked to the obligation to pay the commissions and these commissions are borne by that Permanent establishment, then these commissions will be considered to be born in the contracting state where the permanent establishment is located. + Article 13 Royalty 1. Redevents coming from a Contracting State and paid to a resident of the other Contracting State may be imposed in that State. 2. However, such royalties may also be imposed in the Contracting State from which they originate and in accordance with the legislation of that State but if the recipient is the beneficial owner of the royalties the tax thus established shall not exceed 5 to percent of the gross amount of royalties paid for the use or for the right to use any copyright on a literary, artistic, or scientific work, including cinema films and films or television or radio bands and 7 percent of the gross amount of royalties paid for the use or right of use of any patent, factory brand, design, or model, plan formula or secret procedure, as for the use of industrial, commercial, or scientific equipment or for the information relative to the experience gained in the field industrial, commercial or scientific. The competent authorities of the Contracting States shall, in agreement, determine how to apply this limitation. 3. The provisions of paragraphs 1 and 2 will not apply if the beneficial owner of the royalties, resident of a contracting state, carries out income-producing activities in the other contracting state in which the royalties are born, through a headquarters permanently located there or perform in the other contracting state personal services of an independent nature using a fixed base located there and the right or property in relation to which the royalties are paid are actually related to this headquarters permanent or fixed base. In such cases, the provisions of art. 7 7 or 15, as appropriate. 4. It will be considered that the royalties are born in a contracting state when the payer is that state, an administrative-territorial unit, a local authority or a resident of that state. When, however, the person paying royalties, whether or not he is a resident of a contracting state, has in a contracting state a permanent establishment or a fixed base in relation to which the obligation to pay the royalties and payment of these fees was born. royalties is borne by this permanent establishment or fixed base, then these royalties will be considered to be born in the contracting state in which the permanent establishment or fixed base is located. 5. When, due to the special relations existing between the debtor and the beneficial owner or between both and another person, the amount of the royalties, taking into account the use, concession of the use or the information for which they are paid, exceeds the amount on which would have been agreed upon by the debtor and the beneficial owner in the absence of such relations, the provisions of this Article shall apply only to that latter amount. In this case, the excess part of the payments will remain taxable according to the legislation of each contracting state, taking into account the other provisions of this Convention. + Article 14 Capital gains 1.Cistigs obtained by a resident of a contracting state from the alienation of immovable property, as defined in art. 6, located in the other contracting state, can be imposed in that contracting state. 2.Cistigs coming from the disposal of movable property being part of the asset of a permanent establishment that an enterprise of a contracting state has in the other contracting state, or movable property belonging to a fixed base of which order a resident of a Contracting State in the other Contracting State for the purpose of carrying out personal services of an independent nature, including the gains from the disposal of such permanent establishment (alone or with the whole enterprise) or a fixed base, may be imposed in the other state. 3.The cysts that come from the alienation of ships or aircraft used in international traffic and mobile goods holding the exploitation of these ships or aircraft will be imposed only in the contracting state in which, as a result of the provisions of art. 8 of this convention, the benefits obtained from such activities are taxable. 4.Cistigs obtained from the alienation of any goods, other than those mentioned in paragraphs 1, 2 and 3, shall be imposed only in the contracting state of which the resident is the one who is alienated. + Article 15 Personal services of an independent nature 1.Revenues obtained by a resident of a Contracting State from the exercise of a profession or other self-employed activities shall be imposed only in that State unless the resident is permanently at his disposal in the other state contractor a fixed base for the purpose of exercising the activity or situation in which the resident is present in the other state for a period exceeding 183 days in the course of a fiscal year or periods amounting to 183 days in two years consecutive fiscal. If it has such a fixed base or if the stay exceeds the above-mentioned period, the proceeds will be imposed in the other contracting state, but only to the extent that they can be assigned to that fixed base or period of stay. 2.Expression of free professions includes, in particular, independent scientific, literary, artistic, educational or pedagogical activities, as well as the independent exercise of the profession of doctor, lawyer, engineer, architect, dentist and accountant. + Article 16 Dependent personal services 1.Subject to provisions of art. 17, 19 and 20, salaries and other similar salaries, which a resident of a contracting state receives for a salaried activity are taxable only in that state, unless this activity is exercised in the other state. contractor. If the employed activity is exercised in the other contracting state, the remuneration received from this activity is taxable in that state. 2.Independent of the provisions of paragraph 1, the remuneration that a resident of a contracting state receives for a salaried activity exercised in the other contracting state will be taxable only in the first state mentioned if: a) the recipient remains in the other state for a period or periods not exceeding a total of 183 days during the fiscal year of the other State, and b) the remuneration is paid by a person or on behalf of a person who hires and is not resident of the other State, and c) the remuneration is not borne by a permanent establishment or a fixed base which the employee has in the other state. 3.Independent of the previous provisions of this article, the remuneration for the employed activity on board a ship or an aircraft in international traffic may be taxable in the contracting state from which benefits are obtained from the activity of these vessels or aircraft, in accordance with the provisions of 8. + Article 17 Remuneration of members of the management or management board Directors ' remuneration and other similar remuneration received by a resident of a Contracting State in his capacity as a board member of a resident company in the other Contracting State, may be imposed in that State. + Article 18 Artists and athletes 1.Independent of provisions of art. 15 and 16, the income that a resident of a contracting state, as an artist of theatre, cinema, radio or television and musical interpreters, as well as athletes obtain from their personal activity in the other state contractor, can be imposed in that state. 2.When the income regarding the personal activities exercised by a professional of performances or a sportsman in this capacity does not return to him but to another person, independent of the provisions of art. 7, 15 and 16, those incomes can be imposed in the contracting state in which the activities of the show professional or athlete are carried out. 3.The incomes obtained from such activities, carried out within the framework of the cultural agreements concluded between the contracting states, are mutually exempt from taxes. + Article 19 Pensions Subject to the provisions of paragraph 2 of art. 20, pensions and other similar remuneration paid to a resident of a contracting state for employed work carried out in the past, will be taxable only in that state. + Article 20 Public functions 1. a) Remuneration, other than pensions paid by a contracting state, an administrative-territorial unit or a local authority thereof to any natural person for services rendered to that State, units or authorities, shall be imposed only in that state. b) However, such remuneration will be imposed only in the other contracting state if the services are provided in that state and the person is a resident of that state which: I) is a national of that state, or II) did not become a resident of that state solely for the purpose of providing services. 2.a) Any pension paid by or from funds created by a Contracting State, an administrative-territorial unit or a local authority thereof to a natural person for services rendered to that State, its units or authorities shall be imposed only in that state. b) However, such pensions will be imposed only in the other contracting state, if the person is resident and national of that state. 3.Previews of art. 16 16, 17 and 19 will apply to remuneration and pensions relating to services provided in connection with an income-producing activity carried out by a contracting state, an administrative-territorial unit or a local authority thereof. + Article 21 Teachers 1. The remuneration that teachers and other members of the resident education corps of a contracting state who teach in a university or any other authorized educational institution of the other contracting state receive them for this purpose. activity are taxable only in the first state, for a period not exceeding 2 years from the start of their activity. 2. The provisions of paragraph 1 will also apply to the remuneration that a natural person, resident of a contracting state receives for research works executed in the other contracting state, if such research is not undertaken primarily for the private benefit of an enterprise or persons. + Article 22 Students, trainees and persons in specialisation 1. The amounts that a student, a practitioner, a trainee or a person sent to interest the technical, professional or commercial experience that is or was immediately prior to his presence in a Contracting State, a resident of the other State contractor and who is present in the first contracting state mentioned only for the purpose of his training or preparation, receives them for maintenance, training or preparation, will not be imposed in the first mentioned state provided that such amounts are provina from sources located outside that state. 2. The same exemption will apply to income earned by a person from the above mentioned from the salaried work he provides in that first contracting state to supplement his means for maintenance, education, training and other work. expenses for specialization, for a limited period 2 years after his arrival in that first contracting state. + Article 23 Other income 1. The income elements of a resident of a Contracting State, from wherever they originate, which were not mentioned in the preceding articles of this Convention, shall be imposed only in that State. 2. The provisions of paragraph 1 shall not be applied to income, other than income arising from real estate, as defined in paragraph 2 of art. 6 if the recipient of such income who is a resident of a contracting state, carries out income-producing activities in the other contracting state through a permanent establishment located in it or carries out in that state personal services of an independent nature using a fixed base located in it and the rights or goods with respect to the paid income are actually related to that permanent establishment or fixed base. In such cases, the provisions of art. 7 7 or art. 15 15, as applicable + Article 24 Imposition of wealth 1. The wealth constituted of immovable property, to which art. 6, owned by a resident of a Contracting State and located in the other Contracting State shall be taxed in that State. 2. The wealth constituted of movable property being part of the asset of a permanent establishment that an enterprise of a contracting state has in the other contracting state or from movable property holding a fixed base at the disposal of a resident of a state contractor in the other contracting state, for the purpose of exercising personal services of an independent nature, is taxable in that state. 3. Averea consisting of ships or aircraft operated in international traffic and mobile goods, aiming at the operation of such ships or aircraft are taxable only in the contracting state in which the benefits related to ships or aircraft are taxable in accordance with the provisions of art. 8 8 of this convention. 4. All other assets of a resident of a Contracting State shall be taxable only in that State. + Article 25 Avoiding double taxation 1. When a resident of a Contracting State realizes income or holds wealth which, in accordance with the provisions of this Convention may be imposed in the other Contracting State, the first State mentioned shall grant: a) as a deduction from the income tax of that resident an amount equal to the income tax paid in that state; b) as a deduction from the wealth tax of that resident an amount equal to the wealth tax paid in that state. One such deduction in each state will not, however, exceed that portion of income tax or wealth tax as determined before the deduction, which is, or as the case may be, attributable to income or wealth that may be deducted. be imposed in that state. + Article 26 Nondiscrimination 1. The nationals of a Contracting State shall not be subject in the other Contracting State to any tax or other obligation related to it, which is different or more burdensome than the imposition and the requirements related to this imposition to which they are or may be subject to nationals of the other State under the same conditions 2. The national term indicates: a) all individuals who possess Greek nationality or Romanian citizenship; b) all legal entities, persons companies and associations constituted according to the legislation in force in a contracting state. 3. The imposition of a permanent establishment that an enterprise of a contracting state has in the other contracting state will not be established under less favorable conditions in the other state, than the imposition established to the enterprises of that state which conduct the same activities This provision will not be construed as obliging a Contracting State to grant residents of the other Contracting State any facilitation, reduction or exemption of a personal nature, in respect of the imposition on considerations of civil status or the family responsibilities it grants to its residents. 4. The enterprises of a Contracting State, whose capital is, in whole or in part owned or controlled, directly or indirectly by one or more residents of the other Contracting State, shall not be subject in the first Contracting State mentioned no tax or obligation related to it that is different or more burdensome than the tax or obligations related to it, to which other similar enterprises of the first mentioned state are or may be subject. 5. The provisions of this article will apply to taxes of any kind and nature, independently of the provisions of art. 2. + Article 27 Amicable procedure 1. When a person considers that the measures taken by a Contracting State or both Contracting States attract or may attract them a tax which is not in conformity with this Convention, it may, regardless of the remedies provided for by the legislation national of these states, to submit the case or to the competent authority of the contracting state whose residence is or if its case falls under the provisions of paragraph 1 of art. 26, then it will be presented to the contracting state whose national it is. The case must be presented within 3 years of the first notification of the action resulting from the imposition being contrary to the provisions of the Convention. 2. The competent authority shall endeavour, if the complaint appears to be founded and if it itself is unable to reach an appropriate settlement, to resolve the matter on the way of a mutual understanding with the competent authority of the other State contractor in order to avoid taxation which does not comply with the Convention. 3. The competent authorities of the Contracting States shall endeavour to resolve, on the way of mutual understanding, any difficulties or doubts as to the interpretation or application of the Convention. They may also consult with a view to avoiding double taxation in unforeseen cases of the Convention. 4. The competent authorities of the contracting states may communicate directly with each other in order to achieve a settlement in order to apply the provisions of the preceding paragraphs. When, in order to reach an agreement, an oral exchange of views appears to be advisable, such an exchange may take place within a committee composed of representatives of the competent authorities of the contracting states. 5. The competent authorities of the contracting states shall consult each other, if the changes in their tax legislation require changes to the convention. + Article 28 Exchange of information 1. The competent authorities of the Contracting States shall exchange information if necessary for the application of the provisions of this Convention or of the internal laws of the Contracting States concerning the taxes provided for by the Convention, in where taxation is not contrary to the convention. The exchange of information is not influenced by art. 1. Any information obtained by a Contracting State shall be treated as a secret in the same manner as an information obtained under the conditions of the domestic law of that State and shall be made known only to persons or authorities (including tribunals and administrative bodies) which have powers in connection with the establishment or collection, execution or prosecution or the resolution of appeals in relation to the taxes which are the subject of the Convention. The persons or authorities concerned must use the information only for these purposes. They can make known information in public trials at the courts or in court decisions. 2. The provisions of paragraph 1 shall in no case be construed as imposing an obligation on a Contracting State: a) to take administrative measures contrary to their own legislation or to the administrative practice of one or the other Contracting State; b) to provide information which cannot be obtained on the basis of its own legislation or in the ordinary administrative practice of the two Contracting States; c) to provide information that would disclose any trade secret, professional industrial business or commercial process or information whose disclosure would be contrary to public order. + Article 29 Diplomatic and consular officials No provision of this Convention shall affect the tax privileges enjoyed by diplomatic and consular officials, either by virtue of the general rules of international law or by virtue of the provisions of special agreements. + Article 30 Entry into force 1.The present convention will be ratified and the instruments of ratification will be changed in Bucharest or Athens, as soon as possible. 2.The convention will enter into force after the exchange of the instruments of ratification and its provisions will apply to the income realized on or after the first day of January of the calendar year following that in which the convention entered into force. + Article 31 Denunciation This Convention will remain in force for an indefinite period. Each Contracting State may denounce the Convention by 30 June of each calendar year, starting from the 5th year following the entry into force of the Convention, by a diplomatic denunciation note; in this case the convention will cease to have an effect on the income obtained on or after the first day of January of the calendar year following that in which the denunciation note was given. Right which, the undersigned, authorized in good and due form, we have signed this convention. Concluded on 17 September 1991 in Athens, in 2 original copies, in Romanian, Greek and English, each of the texts being equally authentic, the text in English prevailing in case of divergences.