AGREEMENT

Between

The Government of The Hashemite Kingdom of Jordan

And

For the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income .

___________________________________________________________________

            The Government of The Hashemite Kingdom of Jordan and The Government of

            DESIRING to conclude an Agreement For the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income.

            Have agreed as follows:

Article 1

PERSONAL SCOPE

            This Agreement shall apply to persons who are residents of one or both of the Contracting States.

Article 2

TAXES COVERED

1.         This Agreement shall apply to taxes on income imposed by or on behalf of  each  Contracting State or of its political subdivisions or local authorities , irrespective of the manner in which they are levied .

2.         There shall be regarded as taxes on income all taxes imposed on total income, or on elements of income, including taxes on gains from the alienation of movable or immovable property, taxes on the total amount of wages or salaries paid by enterprises .

3.         The existing taxes to which the Agreement shall apply are  :

            a.          in  Jordan   :

                                                -           the income tax ;

                                                -           the distribution tax;

                                                -           the social service tax;

                                    (Hereinafter referred to as " Jordanian tax ").

            b.          in

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

Article 3

GENERAL DEFINITIONS

1.         For the purposes of this Agreement, unless the context otherwise requires:

            a.            i.        the term "  Jordan " means the territories of the Hashemite Kingdom of Jordan, the territorial waters of Jordan, and the seabed and subsoil of the territorial waters, and includes any area extending beyond the limits of the territorial waters of Jordan, and the seabed and subsoil of any such area, which has been or may hereafter be designated, under the laws of Jordan, and in accordance with international law as an area over which Jordan has sovereign  rights for the purposes of exploring and exploiting the natural resources, whether living or non-living ;

                          ii.        the term

b.            the term " person " includes an individual, a company and any other body of persons ;

            c.            the term " company " means any body corporate or any entity      which is treated as a body corporate for the tax purposes ;

            d.            the terms " enterprise of a Contracting State " and " enterprise of  the other Contracting State " mean respectively an enterprise carried on by a resident of Contracting State and an enterprise carried on by a resident of the other Contracting State ;

e.                       the term " international traffic " means any transport by a ship or aircraft , road or railway transport operated by an enterprise of a Contracting State, except when the ship or aircraft , road or railway transport is operated solely between places in the other Contracting State ;    

            f.            the term " competent authority " means :

                                      i.        in Jordan,

                                                the Minister of Finance or his authorised representative ;

                                    ii.          in

            g.            the term " national " means :

                          i.        any individual possessing the nationality of a Contracting                State;

                          ii.        any legal person, partnership and association deriving its               status as such from the law in force in a Contracting State ;

h.         the term "fixed base" means a permanent place in which professional activities are exercised 

2.         As regards the application of the Agreement by a Contracting State, any term not defined therein shall, unless the context otherwise requires, have the meaning which it has under the law of that State concerning the taxes to which this Agreement applies .

Article  4

RESIDENT

1.         For the purposes of this Agreement, the term " resident of a Contracting State " means any person who, under the laws of that State , is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature .

2.         Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then his status shall be determined as follows :

            a.          he shall be deemed to be a resident of the State in which he has a                         permanent home available to him; if he has a permanent home            available to him in both States, he shall be deemed to be a resident of the State with which his personal and economic relations are           closer ( centre of vital interests ) ;

            b.          if  the State in which he has his centre of vital interests cannot be determined, or if he has not a permanent home available to him in either State, he shall be deemed to be a resident of the State in which he has an habitual abode ;

            c.          if he has an habitual abode in both States or in neither of them, the  competent authorities of the Contracting States shall settle the  question by mutual agreement .

3.         Where by reason of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the  competent authorities of the States shall settle the question by mutual agreement .

Article 5

PERMANENT ESTABLISHMENT

1.         For the purposes of this Agreement, the term " permanent establishment " means a fixed place of business through which the business of an enterprise is wholly or partly carried on.

2.         the term " permanent establishment " includes especially :

            a.          a place of management ;

            b.          a branch ;

            c.          an office ;

            d.          a factory ;

            e.          a workshop ;

            f           a warehouse or premises used as sales outlet;

g.         an industrial exhibition, if also used for sail of goods in industrial   quantities ;

            h.          a mine, an oil or gas well, a quarry or any other place of extraction or exploration of natural resources, drilling rig or working ship used       for exploration of natural resources . 

3.         The term " permanent establishment " likewise encompasses :

a.         a building site, a construction, assembly or installation project or supervisory activities in connection therewith, but only where such site, project or activities continue for a period of more than six months;

b.          the furnishing of services, including consultancy services, by an enterprise through employees or other personnel engaged by the enterprise for such purpose, but only where activities of that nature continue ( for the same or a connected project ) within the country for a period or periods aggregating more than three months within  any twelve month period .

4.         Notwithstanding the preceding provisions of this Article, the term  "permanent establishment " shall be deemed not to include:

            a.          the use of the facilities solely for the purpose of storage or display of  goods or merchandise belonging to the enterprise ;

b.          the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage or display (excluding solicitation of orders along with storage or display) ;

            c.          the maintenance of a stock of goods or merchandise belonging to the                     enterprise solely for the purpose of processing by another enterprise;

            d.          the maintenance of a fixed place of business  solely for the purpose of purchasing goods or merchandise, or of collecting information, for the enterprise ;

e.          the maintenance of a fixed place of business  solely for the purpose of advertising, or for the supply of information (excluding contribution of subscription office with collecting information);

f.          the maintenance of a fixed place of business  solely for any combination of activities mentioned in sub-paragraphs a. to e. , provided that the overall activity of the fixed place of business resulting from this combination is of a preparatory or auxiliary character provided that where any of the above activities materially assists in carrying out of the core activities of the enterprise or is conducted along with such core activities from the same place of business or where such activities exceed the " solely" provision shall be deemed to constitute permanent establishment for the enterprise .

5.         Notwithstanding the provisions of paragraphs 1 and 2,where a person - other than an agent of an independent status to whom paragraph 7 applies - is acting in a Contracting State for or on behalf of an enterprise of the other Contracting State, that enterprise shall be deemed to have a permanent establishment in first-mentioned State in respect of any activities which that person undertakes for the enterprise, if such a person :

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

            b.          has no such authority, but habitually maintains in the first mentioned State a stock of goods or merchandise from which he regularly delivers goods or merchandise for or on behalf of the enterprise ;

            c.          manufactures or processes in that State for the enterprise goods or                       merchandise belonging to the enterprise .

6.         An insurance enterprise of a  Contracting State shall, except with regard to reinsurance, be deemed to have a             permanent establishment in the other Contracting State if it collect premiums in that other State or insures risks situated therein through an employee or through a representative who is not an agent of an independent status within the meaning of  paragraph 7.

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

8.         The fact that a company which is a resident of  a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State ( whether through a permanent establishment or otherwise ), shall not of itself constitute either company a permanent establishment of the other .

Article 6

INCOME FROM IMMOVABLE PROPERTY

1.         Income derived by a resident of a Contracting State from immovable property (including income from agriculture or forestry) situated  in the other Contracting State may be taxed in that other State .

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

3.         The provisions of paragraph 1 shall apply to income derived from the direct use, letting, or use in any other form of immovable property.

4.         The provisions of paragraphs 1 and 3 shall also apply to the income from immovable property of an enterprise and to income from immovable property used for the performance of independent personal services.

Article 7

BUSINESS PROFITS

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

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

 3.         In determining the profits of a permanent establishment, there shall be allowed as deductions expenses which are incurred for the purposes of the permanent establishment, including executive and general administrative expenses so incurred, whether in the State in which the permanent establishment is situated or elsewhere.

 4.         Insofar as it has been customary in a  Contracting State to determine the profits to be attributed to a  permanent establishment on the basis of an apportionment of the total profits of the enterprise to its various parts, nothing in paragraph 2 shall preclude that Contracting State from determining the profits to be taxed by such an apportionment as may be customary ; the method of apportionment adopted shall , however , be such that the result shall be in accordance with the principles contained in this Article .

 5.         For the purposes of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary.

6.                  Where profits include items of income which are dealt with separately in other Articles of this Agreement, then the provisions of those Articles shall not be affected by the provisions of this Article.

7.                  No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise.

 Article 8

INTERNATIONAL TRANSPORT

1.                     Profits from the operation of ships, aircraft or road vehicles in international traffic shall  be taxable only in the Contracting State in which the place of effective management of the enterprise is situated .

 2.                     Profits from the operation of boats engaged in inland waterways transport shall be taxable only in the Contracting State in which the place of effective management of the enterprise is situated.

 3.         If the place of effective management of a shipping enterprise or of an inland waterways transport enterprise is aboard a ship or boat, then it shall be deemed to be situated in the Contracting State in which the home harbor of the ship or boat is situated, or, if there is no such home harbor, in the Contracting State of which the operator of the ship or boat is a resident.

 4.         The provisions of paragraph 1 shall also apply to profits from the participation in a pool, a joint business or an international operating agency.  

 Article 9

ASSOCIATED ENTERPRISES  

1.         Where

            a.          an enterprise of a Contracting State participates directly or indirectly in the management, control or capital of an enterprise of the other Contracting State, or

b.          the same persons participate directly or indirectly in the management, control or capital of an enterprise of a Contracting State and an enterprise of the other  Contracting State, and  in either case conditions are made or imposed between the two enterprises in their commercial or financial relations which differ from those which would be made between independent enterprises, then any profits which would, but for those conditions, have accrued to one of the enterprises, but, by reason of those conditions, have not so accrued, may be included in the profits of that enterprise and taxed accordingly .

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

3.                  A Contracting State shall not change the profits of an enterprise in the circumstances referred to in paragraph 2 after the expiry of the time limits provided in its tax laws.

4.         The provisions of paragraph 2 shall not limit any provisions of the law of the Contracting State which permit the distribution, apportionment or allocation of income, deductions, credit or allowances between persons, whether or not residents of a Contracting State owned or controlled directly or indirectly by the same interests when necessary in order to prevent evasion of taxes or tax fraud or clearly to reflect the income of any such person" In any case, the provisions of paragraph 2 shall not aplly in case of tax fraud.

 Article 10

 DIVIDENDS

1.         Dividends paid by a company which is a resident of a Contracting State to a resident of the other Contracting State may be taxed in that other State.

2.         However, if the beneficial owner of the dividends is a resident of the other Contracting State, the tax charged by the first mentioned State may not exceed  percent of the gross amount of the dividends actually distributed. This paragraph shall not affect the taxation of the company in respect of the profits out of which the dividends are paid.

3.         The term " dividends  " as used in this Article means income from shares, or other rights, not being debt-claims, participating in profits, as well as income from other corporate rights which is subjected to the same taxation treatment as income from shares by the laws of the State of which the company making the distribution is a 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 on business in the other Contracting State of which the company paying the dividends is a resident, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the holding in respect of which the dividends are paid is effectively connected with such permanent establishment or fixed base . In such case the provisions of  Article 7 or Article 14, as the case may be, shall apply.

Article 11

 INTEREST

1.         Interest arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State.

2.         However, such interest may also be taxed in the Contracting State in which it arises and according to the laws of that State, but if the recipient is the beneficial owner of the interest the tax so charged shall not exceed               (       ) percent of the gross amount of the interest .The competent authorities of the Contracting State shall by mutual agreement settle the mode of application of this limitation.

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

4.                     The term " interest  " as used in this Article means income from debt-claims of every kind, whether or not secured by mortgage and whether or not carrying a right  to participate in the debtor's profits, and in particular, income from government securities and income from bonds or debentures, including premiums and prizes attaching to such securities, bonds or debentures , as well as income assimilated to income from money lent. Penalty charges for late payment shall not be regarded as interest for the purpose of this Article.

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

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

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

8.         Where an enterprise of a Contracting State participates directly or indirectly in the management, control or capital of an enterprise of the other Contracting State, or maintains a permanent establishment in the other Contracting State, interest arising in that other State on any loans  extended to such enterprise or permanent establishment shall be disallowed and the provisions of Article 10 shall apply if such enterprise or permanent establishment has initially been inadequately capitalized.

 Article 12

 ROYALTIES AND TECHNICAL SERVICES FEES

 1.         Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State.

2.                  However, such royalties may also be taxed in the Contracting State in which they arise and according to the law of that State, but if the recipient is the beneficial owner of the royalties (as defined in paragraph 4 of this Article), the tax so charged shall not exceed (    ) percent of the gross amount of royalties.

3.                  Notwithstanding the provisions of paragraph 3 (b) of Article 5 and Article 7, where and enterprise of a Contracting State furnishes services , including consulting services , through employees or other personnel engaged by the enterprise for such purpose, to an enterprise in the other Contracting State, the amount received by such enterprise for performing  these services shall be deemed to arise in the other Contracting State and taxed therein , but if the recipient is a beneficial owner of such amount, the tax so charged shall not exceed (        ) percent of the gross amount.

4.                  The term " royalties " as used in this Article means payments, whether periodical or not, and in whatever form or name or nomenclature to the extent to which they are made as consideration for :

 a.                   the use of , or the right to use, any copyright , patent , design or model , plan , secret formula or process, trademark or other like property or right; or

b.                   the use of , or the right to use, any industrial, commercial, or scientific equipment , or

c.                   the supply of scientific, technical, industrial or commercial knowledge or information; or

d.                   the supply of any assistance that is ancillary and subsidiary any such property or right as is mentioned in sub - paragraph ( a), any such equipment as is mentioned in sub - paragraph (b), or any such knowledge or information as is mentioned in sub - paragraph (c); or

e.                   the use of , or the right to use:

i.                     motion picture films; or

ii.                   films or video for use in connection with television; or

iii.                  tapes for use in connection with radio broadcasting; or

f.                     total or partial forbearance in respect of the use or supply or any property or right referred to in this paragraph .

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

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

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

Article 13

CAPITAL GAINS

1.         Gains derived by a resident of a Contracting State from the alienation of immovable property referred to in Article 6 and situated in the  other Contracting State may be taxed in that other State .

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

3.       Gains derived by an enterprise of a Contracting State from the alienation of ships or aircraft operated in international traffic or movable property pertaining to the operation of such ships or aircraft shall be taxable only in that State.

4.    Gains from the alienation of the shares of the capital stock of a company the property of which consists directly or indirectly principally of immovable property situated in the Contracting State  may be taxed in that state.

5.       Gains from the alienation of shares other than those mentioned in paragraph 4 in a company which is a resident of a Contracting State may be taxed in that State provided that such shares represent (      ) percent in that company .

6.       Gains from the alienation of any property other than that referred to in the preceding paragraphs shall be taxable only in the Contracting State where the gains arise.

Article 14

INDEPENDENT PERSONAL SERVICES

1.         Income derived by a resident of a Contracting State in respect of professional services or other activities of an independent character shall be taxable only in that State except in the following circumstances when such income may also be taxed in the other Contracting State:

a.                   If he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities, in that case , only so much of the income as is attributable to that fixed base may be taxed in that other Contracting State ;or

b.                   If his stay in the other Contracting State is for a period or periods amounting to or exceeding in the aggregate 183 days in the fiscal year concerned; in that case, only so much of the income as is derived from his activities performed in that other State may be taxed in that other State; or

c.                    If the remuneration for his activities in the other Contracting State is paid by a resident of that Contracting State or is borne by a permanent establishment or a fixed base situated in that Contracting State and exceeds in the fiscal year -------- U.S Dollars.

            2.          The term " professional services " includes especially independent scientific, literary, artistic, educational or teaching activities as well as the  independent activities of physicians, lawyers, engineers, architects, dentists and accountants .

Article 15

DEPENDENT PERSONAL SERVICES

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

 2.         Notwithstanding the provisions of paragraph 1,  remuneration derived by a resident of a Contracting State in respect of an employment  exercised in the other Contracting State shall be taxable only in the  first-mentioned State if :

             a)         the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in any twelve-months period commencing or ending in the fiscal year concerned, and

            b)         the remuneration is paid by, or on behalf of, an employer who is not   a resident of the other State, and

            c)          the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State .

3.         Notwithstanding the preceding provisions of this Article,   remuneration derived in respect of an employment  exercised aboard a ship or aircraft operated in international traffic, or aboard a boat engaged in inland waterways transport , shall be  taxed in the Contracting State  in which the place of effective management of the enterprise is situated .

Article 16

DIRECTOR'S FEES AND REMUNERATIONS OF TOP LEVEL MANAGEMENT OFFICEALS

1.                  Director's fees and other similar payments derived by a resident of a Contracting State in his capacity as a member of the board of directors of a company which is a resident of the other Contracting State may be taxed in that other  Contracting State .

2.                   Salaries wages and similar remuneration derived by a resident of a Contracting State in his capacity as an official in a top - level managerial position of a company which is a resident of the other Contracting State may be taxed in that other State. 

Article 17

ARTISTES AND SPORTSMEN

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

2.         Where income in respect of personal activities exercised by an entertainer, or a sportsman in his capacity as such accrues not to the entertainer or sportsman himself but to another person, that income may, notwithstanding the provisions of  Articles 7, 14 and 15, be taxed in the Contracting State in which the activities of the entertainer or sportsman are exercised.

Article 18

PENSIONS AND ANNUITY

1.                  Subject to the provisions of  paragraph 2 of Article 19, pensions and other similar remuneration paid to a resident of a Contracting State from a source  in the other Contracting State in  consideration of past employment or services in the other Contracting State and any annuity paid to such a resident from such a source  shall be taxable only  in that other  State.

2.                   The term "annuity " means a stated sum payable periodically at a stated times during life or during a  specified or ascertainable period of time under an obligation to make the payments in return for adequate and full consideration in money or money's worth.    

Article 19

GOVERNMENT SERVICE

1.         a)         Salaries, wages and other remuneration, other than a pension,  paid by a Contracting State or a political subdivision or a local authority thereof to an individual in respect of services rendered to that State or subdivision or authority shall be taxable only in that State.

             b)         However, such salaries, wages and other remuneration shall be taxable only in the other Contracting State if the services are rendered in that State and the individual is a resident of that State who :

                                     i.         is a national of that State; or

                                    ii.          did not become a resident of that State solely for the purpose                                of rendering the services .                            

 2.         a)         Any pensions paid by, or out of funds created by, a Contracting State                      or a political subdivision or a local authority thereof to an individual in respect of services rendered to that State or subdivision or local authority thereof shall be taxable only in that State.

 b)         However, such pension shall be taxable only in the other Contracting State if the individual is a resident of, and a national of that State.

 3.         The provisions of Articles 15, 16 and 18 shall apply to remuneration, and to pensions, in respect of services rendered in connection with a business carried on by a Contracting State or a political subdivision or a local authority thereof.

 Article 20

TEACHERS AND RESEARCHERS

            An individual who is or was immediately before visiting a Contracting State a resident of the other Contracting State and who, at the invitation of the Government of the first - mentioned Contracting State or of a University, college, school, museum or other cultural institution in that first-mentioned Contracting State or under an official program of cultural exchange, is present in that Contracting State for a period not exceeding    (      ) solely for the purpose of teaching, giving lectures or carrying out research at such institution shall be exempt from tax in that Contracting State on his remuneration for such activity, provided that payment of such remuneration is derived by him from outside that Contracting State. 

Article 21

STUDENTS AND TRAINEES

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

2.         In respect of grants, scholarships and remuneration from employment not covered by paragraph I , a student or business trainee described in paragraph I shall, in addition, be entitled during such education or training to the same exemption, relieves or reductions in respect of taxes available to residents of the Contracting State which he is visiting. Provided that no exemption shall be available to the remuneration from employment beyond a period of 4 years.

Article 22

OTHER INCOME

            Items of income of a resident of a Contracting State, which are not expressly mentioned in the foregoing Articles of this Agreement shall be taxable only in that State except that , if such income is derived from sources within the other Contracting State, it may also be taxed in that other State.

Article  23

ELIMINATION OF DOUBLE TAXATION

1.                   Where a resident of a Contracting State derives income from the other Contracting  State , which , in accordance with the provisions of this convention, may be taxed in the other Contracting State , the first mentioned State shall relieve its resident of the effects of double taxation either (a) by allowing as a deduction from the tax on the income of that resident an amount equal to the income tax paid in that State ( but not exceeding the part of the income tax as computed before the deduction is given, which is attributable, as the case may be, to the income which may be taxed in that other State); or (b) by exempting such income from tax subject to the provisions of paragraph 2.

2.         Where in accordance with any provision of this convention income derived by a resident of a Contracting State is exempt from tax in that State , such State may nevertheless, in calculating the amount of tax on the remaining income of such resident, take into account the exempted income.

2.                   In the case of Jordan

In the case of

Article  24

NON - DISCRIMINATION

1.         Nationals of a Contracting State shall not be subjected in the other Contracting State to any taxation or any requirement connected therewith, which is other or more burdensome than the taxation and connected requirements to which nationals of that other State in the same circumstances, in particular with respect to residence, are or may be subjected . The provision shall, notwithstanding the provisions of Article 1, also apply to persons who are not residents of one or both of the  Contracting States .

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

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

4.         Except where the provisions of paragraph 1 of Article 9,  paragraph  7   of Article 11, or of paragraph 6 of Article 12  apply, interest, royalties and other disbursements paid by an enterprise of a Contracting State to a resident of the other Contracting State shall, for the purpose of determining the taxable profits of such enterprise, be deductible under the same conditions as if they had been paid to a resident of  the first-mentioned State .

 5.                  In this Article the term " taxation " means taxes which are the subject of this Agreement.

Article 25

MUTUAL AGREEMENT PROCEDURE

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

 2.         The competent authority shall endeavour, if the objection appears to it to be justified and if it