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 Contracting State except in one of 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 to much of the income as is attributable to that fixed base may be taxed in that other Contracting State; 　　(b) if his stay in the other Contracting State is for a period or periods exceeding in the aggregate 183 days in the calendar year concerned; in that case, only so much of the income as is derived from his activities performed in that other Contracting State may be taxed in that other Contracting State. 　　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, 19, 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 Contracting 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 Contracting State. 　　2. Notwithstanding the provisions of paragraph 1, remuneration derive 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 Contracting State for a period or periods not 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 Contracting State; and (c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other Contracting State. 3. Notwithstanding the provisions of paragraphs 1 and 2 of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated by an enterprise which is a resident of a Contracting State in international traffic, shall be taxable only in that Contracting State. 　　Article 16 Directors' Fees Directors' fees and other similar payments derived by a resident of a Contracting State in his capacity as a member of the beard of directors of a company which is a resident of the other Contracting State may be taxed in that other Contracting 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 Contracting State. 2. Where income in respect Of personal activities exercised by an entertainer or a sportsman in his capacity as such accrues no 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. 3. Notwithstanding the provisions of paragraphs 1 and 2, income derived by entertainers or sportsmen who are residents of a Contracting State from the activities exercised in the other Contracting State under a p1an of cultura1 exchange between the Governments of both Contracting States 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 Contracting State. 　　Article 19 Government Service 　 1. (a) Remuneration, other than Pension, Paid by the Government of a Contracting State, a political subdivision or a local authority thereof to an individual in respect of services rendered to the Government of that Contracting State, a political subdivision or a local authority thereof, in the discharge of functions of a governmental nature, shall be taxable only in that Contracting State. 　　(b) However, such remuneration shall be taxable only in the other Contracting State if the services are rendered in that other Contracting State and the individual is a resident of that other Contracting State who: 　　(i) is a national of that Contracting State; or 　　(ii) did not become a resident of that other Contracting State solely for the purpose of rendering the services. 　　2. (a) Any pension paid by, or out of funds to which contributions are made by the Government of a Contracting State, a political subdivision or a local authority thereof to an individual in respect of services rendered to the Government of that Contracting State, a political subdivision or a local authority thereof shall be taxable only in that Contracting 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 other Contracting State. 3.The provisions of Articles 15,16,17 and 18 shall apply to remuneration and pensions s in respect of services rendered in connection with a business carried on by the Government of a Contracting State, a political subdivision or a local authority thereof. 　　Article 20 Teachers 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 primary purpose of teaching, giving lectures or conducting research at a university, college, school or educational institution or scientific research institution accredited by the Government of the first-mentioned Contracting State shall be exempt form tax in the first-mentioned Contracting State, for a period of three years from the date of his arrival in the first-mentioned Contracting State, in respect of remuneration for such teaching, lectures or research. 　　Article 21 Students and Trainees 　　A student 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 State solely for the purpose of his education or training shall be exempt from tax in that first-mentioned State on the following payments or income received or derived by him for the purpose of his maintenance, education or training: 　　(a) payments derived from sources outside that Contracting State for the purpose of his maintenance, education, study, research or training; 　　(b) grants, scholarships or awards supplied by the Government, or a scientific, educational, cultural or other tax-exempt organization. 　　Article 22 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 or 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. 　　Article 23 Property 　　1. Property represented by immovable property referred to in Article 6, owned by a resident of a Contracting State and situated in the other Contracting State, may be taxed in that other Contracting State. 　　2. Property represented by 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 by 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, may be taxed in that other Contracting State. 　　3. Property represented by ships or aircraft owned by an enterprise which is a resident of a Contracting State and operated in international traffic or by movable property pertaining to the operation of such ships or aircraft shall be taxable only in that Contracting State. 　　4. All other elements of property of a resident of a Contracting State shall be taxable only in that Contracting State. 　　Article 24 Methods for the Elimination of Double Taxation 　　1. In Armenia, double taxation shall be eliminated as follows: 　　(a) where a resident of Armenia derived income or owns property which, in accordance with the provisions of this Agreement, may be taxed in China, Armenia shall allow: 　　(i) as a deduction from the tax on the income of that resident, an amount equal to the income tax paid in China; 　　(ii) as a deduction from the tax on the property of that resident, an amount equal to the property tax paid in China. 　　Such deduction in either case shall not, however, exceed that part of the income tax or property tax, as computed before the deduction is given, which is attributable, as the case may be ,to the income or the property which may be taxed in China; 　　(b) where in accordance with any provisions of this Agreement income derived or property owned by a resident of Argmenia is exempt from tax in Armenia, Armenia may nevertheless, in calculating the amount of tax on the remaining income or property of such resident, take into account the exempted income or property. 　　2. In China, double taxation shall be eliminated as follows: Where a resident of China derives income from Armenia the amount of tax on that income payable in Armenia in accordance with the provisions of this Agreement, may be credited against the Chinese tax imposed on that resident. The amount of the credit, however, shall not exceed the amount of the Chinese tax on that income computed in accordance with the taxation law and regulations of China. 　　Article 25 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 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 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 paragraph 2 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 had been paid to a resident of the first-mentioned State. Similarly, any debts of an enterprise of a Contracting State to a resident of the other Contracting State shall, for the purpose of determining the taxable property of such enterprise, be deductible under the same conditions as if they had been contract to a resident of the first-mentioned State. 4. Enterprises of a Contracting State, the property 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 the 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 26 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 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 25, 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 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 which is not in accordance with this Agreement. Any agreement reached shall be implemented notwithstanding any time limits in the domestic law of the Contracting States. 3. The competent authorities of the Contracting States shall endeavour to resolve by mutual agreement any difficulties or doubts arising as to the interpretation or application of the Agreement. They may also consult together for the elimination of double taxation in cases not provided for in the Agreement. 4. The competent authorities of the Contracting States 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 agreement, representatives of the competent authorities of the Contracting States may meet together for an oral exchange of opinions. 　　Article 27 Exchange of Information 1. The competent authorities of the Contracting States shall exchange such information as is necessary for carrying out the provisions of this Agreement or of the domestic laws of the Contracting States concerning taxes covered by the Agreement, insofar as the taxation thereunder is not contrary to the 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 and shall be disclose 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 on1y 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 administrative practice of that or of the other Contracting State; (b) to supply information which is not obtainable under the law or in the normal course of the administration 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 (ordre public). 　　Article 28 Members of Diplomatic Missions and Consular Posts 　　Nothing in this Agreement shall affect the fiscal privileges of members of diplomatic missions or consular posts under the general rules of international law or under the provisions of special agreements. 　　Article 29 Entry into Force 　 This Agreement 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: (a) in respect of taxes withheld at source, to income derived on or after 1 January in the calendar year next following that in which the Agreement enters into force; (b)in respect of other taxes, to taxes chargeable for any taxable year beginning on or after 1 January in the calendar year next following that in which the Agreement enters into force. 　　Article 30 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 channels. In such event this Agreement shall cease to have effect: 　　(a) in respect of taxes withheld at source, to income derived on or after 1 January in the calendar year next following that in which the notice of termination is given; 　　(b) in respect of other taxes, to taxes chargeable for any taxable year beginning on or after 1 January in the calendar year next following that in which the notice of termination is given. 　　IN WITNESS WHEREOF the undersigned, duly authorized thereto, have signed this Agreement. 　　DONE at Beijing on the fifth day of May, 1996, in duplicate in the Chinese, Armenian and English languages, all texts being equally authentic. In the case of any divergence of interpretations, the English text shall prevail. For the Government of the People's 　　For the Government of the Republic Republic of China　　　　　　　　　　　of Armenia