Article 15 Dependent Personal Services 　　1. Subject to the provisions of Article 16, 18, l9, 20 and 21, 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 no exceeding in the aggregate 183 days in the calendar year concerned, and 　　(b) the remuneration is paid by, or on behalf of , an employer who is no a resident of the other State, and 　　(c) the remuneration is no 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, may be taxed in the Contracting State in which the place of head office or the place of effective management of the enterprise is situated. 　　Article 16 Directors' Fees 　　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 State. 　　Article 17 Artists and Athletes 　　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 artist, or a musician, or as an athlete, from his personal activities as such exercised in the other Contracting State, may be taxed that other State. 　　2. Where income in respect of personal activities exercised by an entertainer on an athlete in his capacity as such accrues not to the entertainer or athlete 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 athlete are exercised. 　　3. Notwithstanding the provisions of paragraphs 1 and 2, income derived by entertainer or athletes who are residents of a Contracting State from the activities exercised in the other Contracting State under a plan of cultural exchange between the Governments of both Contracting State shall be exempt from tax in that other Contracting State. 　　Article 18 Pensions 　　Subject to the provisions of paragraph 2 of Article 19, pensions and other similar remuneration paid to a resident of a Contracting State in consideration of past employment shall be taxable only in that State. 　　Article 19 Government Service 　　1. (a) Remuneration, other than a pension, paid by a Contracting State or a political or administrative subdivision or a local authority thereof to any individual in respect of services rendered to that state or subdivision or authority shall be taxable only in that State. 　　(b) However, such 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 pension paid by, or out of funds created by, a Contracting State a political or administrative 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 pension shall be taxable only in the other Contracting State if the individual is a national of and a resident of that State. 　　3. The provisions OF Articles 15, 16, 17 and 18 shall apply to remuneration and pensions in respect of services rendered in connection with a business carried on by one of the Contracting State or a political or administrative subdivision or a local authority thereof. 　　Article 20 Teaches and Researchers 　　An individual who is, or immediately before visiting a Contracting State was, a resident of the other Contracting State and is present in the first-mentioned Contracting State for the purpose of teaching, giving lectures or conducting research at a university, college, school or educational institution or scientific research institution shall be exempt form tax in the first mentioned Contracting State, for a period not exceeding three years from the date of his first arrival in the first-mentioned Contracting State in respect of remuneration for such teaching, lectures or research. 　　Article 21 Students and Trainees 　　1. Payments which a student, business apprentice or trainees 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 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 Contracting State. 　　2. Remuneration which a student, business apprentice or trainee who is or was immediately before visiting a contracting State a resident of the other Contracting State derives form an employment which he exercises in the first-mentioned State for the purpose of his education or training shall not be taxed in that first-mentioned State. 　　3. The exemptions under paragraph 1 of this Article shall only continue for such a period of time as may reasonably or customarily be required to complete the education or training be required to complete the education or training undertaken but in no event shall any individual have the benefit of paragraph 1 of this Article for more than 5 years from the commencement of such education or training. 　　Article 25 Other Income 　　1. Items of income of a resident of a Contracting State, wherever arising, not dealt with in the foregoing Articles of this Agreement shall be taxable only in that State. 　　2. The provisions of paragraph 1 shall not apply to income, other than income from immovable property as defined in paragraph 2 of Article 6, if the recipient of such income being a resident of a Contracting State, carries on business in the other Contracting State 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 income is 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. 　　3. Notwithstanding the provisions of paragraphs 1 and 2, items of income of a resident of a Contracting State not dealt with in the foregoing Article of this Agreement and arising in the other Contracting State may be taxed in that other Contracting State. 　　Article 23 Elimination of Double Taxation 　　1. It is agreed that double taxation shall be avoided in accordance with the following paragraphs of this Article. 　　2. If a resident of Italy owns items of income which are taxable in China, Italy, in determining its income taxes specified in Article 2 of this Agreement, may include in the basis upon which such taxes are imposed the said items of income, unless specific provisions of this Agreement otherwise provide. 　　In such case, Italy shall deduct from the taxes so calculated the income tax paid in China but in an amount not exceeding that proportion of the aforesaid Italian tax which such items of income bear to the entire income. 　　However no deduction will be granted if the item of income is subjected in Italy to a final withholding tax by request of the recipient of the said income in accordance with the Italian law. 　　3. In the case of a resident of China: 　　(a) Where a resident of the People's Republic of China derives income from Italy, the amount of tax payable in Italy in respect of that income in accordance with the provisions of this Agreement shall be allowed as a credit against the Chinese tax imposed on that resident. The amount of credit, however, shall not exceed the amount of the Chinese tax computed as appropriate to that income in accordance with the taxation laws and regulations of the People's Republic of China. 　　(b) Where the income derived from Italy is a dividend paid by a company which is a resident of Italy to a company which is a resident of the people's Republic of China and which owns not less than 10 per cent of the shares of the company paying the dividend, the credit shall take into account the tax payable in Italy by the company paying the dividend in respect of its income. 　　4. For the purposes of paragraphs 2 and 3 of this Article where a tax on business profits, dividends, interest or royalties arising in a Contracting State is exempted or reduced for a limited period of time in accordance with the laws and regulations of that State, such tax which has been exempted or reduced shall be deemed to have been paid at a full amount in the case of business profits and at an amount not exceeding. 　　(a) 10% of the gross amount of the dividends and interest referred to under Articles 10 and 11; 　　(b) 15% of the gross amount of the royalties referred to under Article 12. 　　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 are or may be subjected. This provisions 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 favourably levied in that other State than the taxation levied on enterprises 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, reliefs and reductions for taxation purposes on account of civil status or family responsibilities which it grants to its own residents, 　　3. Except where the provisions of Article 9, paragraph 7 of Article 11, or 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 has 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 of the other Contracting State, shall not be subjected in the first-mentioned Contracting 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. 　　5. The provisions of this Article shall, notwithstanding the provisions of Article 2, apply to taxes of every kind and description. 　　Article 25 Mutual Agreement Procedure 　　1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with this Agreement, he may, notwithstanding the remedies provided by the national laws 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 two years from the first notification of the action resulting in taxation not in accordance with the provisions of this Agreement. 　　2. The competent authority shall endeavour, if the objection appears to it to be justified and if it is not itself able to arrive at a satisfactory solution, to resolve the case by mutual agreement with the competent authority of the other Contracting State, with a view to the avoidance of taxation not in accordance with the Agreement. 　　3. The competent authorities of the Contracting State shall endeavour to resolve by mutual agreement any difficulties or doubts arising as to the interpretation or application of the Agreement. 　　4. The competent authorities of the Contracting State may communicate with each other directly for the purpose of reaching an agreement in the sense of paragraphs 2 and 3. When it seems advisable for reaching an agreement, representatives of the competent authorities of the Contracting States may meet together for an oral exchange of opinions. Article 26 Exchange of Information 　　1. The competent authorities of the Contracting States shall exchange such information as is necessary for carrying out provisions of this Agreement or of the domestic laws of the Contracting States concerning taxes covered by the Agreement in so far as the taxation thereunder is not contrary to this Agreement, in particular for the prevention of evasion of such taxes. The exchange of information is not restricted by Article 1. Any information received by a Contracting State shall be treated as secret in the same manner as information obtained under the domestic laws of that State and shall be disclosed only to persons or authorities (including courts and administrative bodies) involved in the assessment or collection of, the enforcement or prosecution in respect of, or the determination of appeals in relation to, the taxes covered by the Agreement. Such persons or authorities shall use the information only for such purposes. They may disclose the information in public court proceedings or in judicial decisions. 　　2. In no case shall the provisions of paragraph 1 be construed so as to impose on a Contracting State the obligation: 　　(a) to carry out administrative measures at variance with the laws and the administrative practice of that or of the other Contracting State; 　　(b) to supply information which is not obtainable under the laws or in the normal course of the administrative practice of that or of the other Contracting State; 　　(c) to supply information which would disclose any trade, business, industrial, commercial or professional secret or trade process, or information, the disclosure of which would be contrary to public policy (odre public). 　　Article 27 Diplomatic Agents and Consular Officers 　　Nothing is this Agreement shall affect the fiscal privileges of diplomatic agents or consular officers under the general rules of international law or under the provisions of special agreements. 　　Article 28 Entry into Force 　　This agreements shall enter into force on the thirtieth day after the date on which diplomatic notes indicating the completion of internal legal procedures necessary in each country for the entry into force of this Agreement have been exchanged. This Agreement shall have effect as respects income derived during the taxable years beginning on or after the first day of January in the calendar year next following that in which this Agreement enters into force. 　　Article 29 Termination 　　This Agreement shall continue in effect indefinitely, but either of the Contracting States may, on or before the thirtieth day of June in any calendar year beginning after the expiration of a period of five years from the date of its entry into force, give written notice of termination to the other Contracting State through the diplomatic channel. In such event this Agreement shall cease to have effect as respects income derived during the taxable years beginning on or after the first day of January in the calendar year next following that in which the notice of termination is given. 　　DONE in duplicate at Beijing, the 31st day of October of the year 1986, in the Chinese, Italian and English languages, all texts being equally authoritative, except in the case of doubts, when the English text shall prevail. For the Government of the People's For the Government of the Republic Republic of China of Italy