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cannot however exceed that proportion of the Israeli tax which the item of capital owned in Italy bears to the entire capital.

2. Where, under the laws of one of the Contracting States, any tax to which this Convention applies has been wholly relieved or reduced for a limited period of time then, for the purposes of calculating the deduction from the tax as referred to in paragraph 1 (a) or the credit referred to in paragraph 1 (b), such tax shall be deemed to have been paid.

Article XX. 1. The 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.

2. The term "nationals" means:

(a) All individuals possessing the nationality of a Contracting State;

(b) All legal persons, partnerships and associations deriving their status as such from the law in force in a Contracting State.

3. Stateless persons shall not be subjected in a 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 State in the same circumstances are or may be subjected.

4. 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 under the same conditions.

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.

5. 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.

6. The provisions of paragraphs 4 and 5 shall not be construed as affecting the imposition in Italy of the tax on companies (imposta sulle società) charged according to the Italian law.

7. In this Article the term "taxation" means taxes of every kind and description.

Article XXI. 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 this Convention, he may, notwithstanding the remedies provided by the national laws of those States, lodge a claim to the competent authority of the Contracting State of which he is a resident. Such claim must be lodged within two years from the date of the notification or withholding at the source of the tax lastly imposed.

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