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Article V. Debts resting upon any of the assets referred to in article III of this Convention or secured by any such assets shall be deducted in the State in which such assets are chargeable with tax, for the value of such assets, or of any other assets which that State has the right to charge with tax. Debts other than the aforesaid shall be deducted from the value of the assets chargeable with tax in the State in which the deceased was domiciled at the time of his death.

If the debts which under the first paragraph are deductible in one of the two States exceed the total value of the assets which that State has the right to charge with tax, the excess shall be deducted from the value of the assets chargeable with tax in the other State.

Article VI. No tax shall be imposed on assets which a deceased person, who at the time of his death was domiciled in one of the Contracting States, willed to any of the following:

(1) The other Contracting State;

(2) A local authority in the other Contracting State for religious, educational, cultural, charitable or welfare purposes;

(3) An institution established or to be established in the other Contracting State for any of the said purposes and approved in that behalf by such State.

Article VII. The competent authorities of the Contracting States shall furnish each other with the informations required for the implementation of the provisions of this Convention, as far as such informations are available under their respective fiscal laws. Informations so supplied shall be kept secret and shall be disclosed only to those (including judicial authorities) who are interested in the assessment and collection of, or in appeals relating to, taxes dealt with by this Convention. No information shall be supplied by which a secret or an industrial or commercial process is likely to be disclosed.

Article VIII. Any taxpayer who proves that taxes imposed or intended to be imposed on him involve or may involve double taxation contrary to the principles of this Convention may lodge objection with the competent authority of the State in which he is considered domiciled under article IV or in which the deceased was considered domiciled under this Convention at the time of his death.

If the objection is found to be justified, the State shall adopt the necessary measures to end the double taxation.

Objection shall be lodged within three years from the end of the solar year in which the taxpayer learned of the double taxation.

Article IX. The provisions of this Convention shall not be construed as negating or impairing in any way the right of diplomatic or consular personnel to other or greater exemptions now enjoyed by them or which may be granted them in the future.

The provisions of this Convention shall in no case be construed as increasing the burden of taxation in either of the Contracting States.

Where doubts or difficulties arise concerning the interpretation or application of this Convention, the competent authorities of the Contracting States may settle the matter by mutual agreement.

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