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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.


Procedural Rules for the Taxation of Income Sources

(1) Where, in a Contracting State, taxes are levied at the time of withdrawal on dividends, interest, royalties, or other sources of income drawn by a resident of the other Contracting State, then the right to impose taxation on such income by the first-mentioned Contracting State in accordance with the provisions of its domestic tax laws shall not be affected by the provisions of this Convention. Taxes on income derived in such a manner are to be returned to the taxpayer on an application filed by the taxpayer to the extent that it is compensated for or ruled out by this Convention.

(2) Income tax return applications shall be completed by the taxpayer within the time limit set forth by the domestic tax laws of the Contracting States or, if this time limit is less than four years, then before the end of the fourth calendar year following the year in which the calculation of tax on dividends, interest, royalties or other sources of income are submitted.

(3) The Contracting State in which the income arises shall demand a written proof of residency from the competent authorities of the other Contracting State.

(4) The competent authorities of both Contracting States may enter into a mutual agreement to establish procedures for execution of the provisions of this Article or any other tax repayment or tax exemption procedures set forth in this Convention.