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Note: This Treaty may be impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). MLI impact on Tax Treaties is available with the Orbitax International Tax Research & Compliance Expert.


Entry into Force

(1) Each Contracting State shall notify to the other the completion of the Constitutional procedures required as far as it is concerned for the bringing into force of this Convention. This Convention shall enter into force on the day when the latter of these notifications has been received and its provisions shall have effect:

  • (a) in respect of taxes withheld at source, to amounts derived on or after 1st January, 1993,
  • (b) in respect of other taxes on income, to taxes chargeable for any taxable period beginning on or after 1st January, 1993.

(2) Claims for refund or credits arising in accordance with this Convention in respect of any tax payable by residents of either of the Contracting States referring to the periods beginning on or after 1st January 1993 and until the entry into force of this Convention shall be lodged within two years from the date of entry into force of this Convention or from the date the tax was charged, whichever is later.