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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.


Methods of Taxation at Source

(1) Where, in a Contracting State, dividends, interest, royalties or any other income derived by a resident of the other Contracting State are taxed by way of deduction at source, the provisions of this Convention shall not affect the right of the first-mentioned State to apply withholding at the rate prescribed by its domestic legislation. This withholding tax shall be refunded upon the applicant's request, if and insofar as it is reduced or abolished by the Convention.

(2) Claims for refund must be submitted before the end of the fourth calendar year following the establishment of tax at source on dividends, interest, royalties or other income.

(3) Notwithstanding the provisions of paragraph (1) of this Article, each Contracting State shall make arrangements to ensure that the payment of income which, by virtue of the present Convention, is not subject to any tax in the source State or is only subject to a reduced tax, may be carried out without withholding tax at source or only with the withholding tax referred to in the relevant Article.

(4) The Contracting State from where the income arises may require an attestation certificate from the competent authority of the other Contracting State certifying the residence in that other State.

(5) The competent authorities may, by mutual agreement, determine the modalities of application of this Article and make, where appropriate, other provisions for the implementation of reductions or exemptions from tax under the Convention.