Page:UN Treaty Series - vol 1332.pdf/137

The Government of the State of Israel and the Government of the Italian Republic, desirous of concluding a convention between them for the avoidance of double taxation with respect to taxes on income and capital, have agreed upon the following articles:

Article 1. 1. This Convention shall apply to taxes on income and capital imposed on behalf of each Contracting State irrespective of the manner in which they are levied.

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

3. The existing taxes to which this Convention shall apply are in particular:

(a) In the case of Israel:

(i) The income tax; including

(ii) The company tax;

(iii) Land betterment tax; and

(iv) Property tax and compensation fund law 1961.

(b) In the case of Italy:

(i) The tax on land (imposta sul reddito dei terreni);

(ii) The tax on buildings (imposta sul reddito dei fabbricati);

(iii) The tax on income from movable wealth (imposta sui redditi di ricchezza mobile);

(iv) The tax on agricultural income (imposta sui redditi agrari);

(v) The complementary tax (imposta complementare progressiva sul reddito [complessivo]);

(vi) The tax on companies (imposta sulle societi); and

(vii) The tax on bonds (imposta sulle obbligazioni).

4. This Convention shall also apply to any identical or substantially similar taxes which are subsequently imposed on behalf of each Contracting State in addition to, or in place of, the existing taxes. At the end of each year, the competent authorities of the Contracting States shall notify to each other any changes which have been made in their respective taxation laws.

5. The competent authorities of the Contracting States shall by mutual agreement resolve any doubts which may arise as to the taxes to which this Convention ought to apply.

Vol. 1332, I-22351

1. ↑ Came into force on 8 August 1973, upon exchange of the instruments of ratification, which took place at Jerusalem, in accordance with article XXIV.