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.



(1) In the event that, in a Contracting State, taxes on dividends, interest, royalties, or other income derived by a resident in the other Contracting State are levied through withholdings (at the source), the right of the first-mentioned State to withhold taxes at the rate set forth in its domestic laws shall not be affected by the provisions of this Convention. At the request of the taxpayer, the tax levied through withholding (at the source) shall be reimbursed provided such tax is reduced or eliminated pursuant to the provisions of this Convention.

(2) Reimbursement requests must be filed prior to the end of the fourth calendar year following the assessment of the tax withholding on dividends, interest, royalties, or other income. After the expiration of this period, the right to reimburse the tax in accordance with sentence 2 of paragraph (1) shall lapse.

(3) The Contracting State in which such income originates shall be entitled to request the applicant to provide an official statement by the competent authority certifying his or her residence in the other Contracting State.

(4) The competent authorities of the Contracting States shall settle the mode of application of this Article by mutual agreement and in case of a requirement, shall specify other procedures for implementation of tax reduction or exemptions provided in this Convention.