background image
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.

ARTICLE 27

Special Provisions

Government investments (including the Central Bank, other financial bodies and institutions wholly owned by a Contracting State or local governments thereof) as well as income derived from such investments (including incomes resulting from the alienation thereof) shall be tax-exempted in the other Contracting State. The provisions of this Article shall not apply to immovable property nor the income generated there from.