LŲ. বাংলাদেশ গেজেট, অতিরিক্ত, জানায়ারী ২, ১৯৯৪ (f) income to which Article 17 applies; ) income from immovable property to which Atricle 6 applies. This shall not apply if the immovable property from which such income arises is effectively connected with a pernament establishment referred to in Article 7 and situated in the Federal Republic of Germany or with a fixed base referred to in Article 14 and situated in the Federal Republic of Germany. Article 23 Non-discrimination 7. Nationals of a Contracting State shall not be subjected in the other contracting State to any taxation or any requirement connected there with, which is other or more burdensome than the taxation and connected requirements to which nationals of that other State in the same circumstances are or may be subjected. This 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 favourable levied in that other State than the taxation levied on enterprises of that other State carrying on the same activities. 3. Except where the provisions of Article 9, paragraph 7 of Article 11, or aragraph 6 of Article 12, apply, interest, royalties and other disbursements paid 影 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. 4. Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents or the other Contracting State, shall not be subjected in the first-mentioned State to any taxation or any requirement connected there with which is other or more burdensome than the taxation and connected requirements to which other similar enterprises of the first-mentioned State are or may be subjected. 5. Nothing contained in paragraphs 1, 2 and 4 of this Article shall be construed as obliging a Contracting State to grant to residents of the other contracting State any reliefs, reductions and personal allowances, which it grants to its own residents.
