ARTICLE 28
Procedural Rules for Taxation at Source
(1) If in one of the Contracting States the taxes on dividends, interest, royalties or other items of income derived by a person who is a resident of the other Contracting State are levied by withholding at source, the right of the first-mentioned State to apply the withholding of tax at the rate provided under its domestic law shall not be affected by the provisions of this Agreement. The tax withheld at source shall be refunded on application by the taxpayer if according to this Agreement, there is no or reduced source tax.
(2) Refund applications must be submitted within the time limits in accordance with the provisions of the laws of the Contracting State in which the items of income arise.
(3) Notwithstanding paragraph 1, each Contracting State shall provide for procedures to the effect,
- (a) that payments of income subject under this Agreement to no tax in the state of source may be made without deduction of tax;
- (b) that payments of income subject under this Agreement to reduced tax in the state of source may be made with deduction of tax only at the rate provided for in the relevant Article.
(4) The Contracting State in which the items of income arise may ask for a certificate by the competent authority on the residence in the other Contracting State.
(5) The competent authorities may by mutual agreement implement the provisions of this Article and if necessary establish other procedures for the implementation of tax reductions or exemptions provided for under this Agreement.