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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 Taxation at Source

(1) If in a Contracting State 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 Contracting 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 and to the extent that it is reduced or ceases to be levied in accordance with the Agreement.

(2) Applications for refund of the withholding taxes of a Contracting State which are subject to reduction or exemption under this Agreement shall be submitted within the period provided for in the domestic law of that Contracting State.

(3) Each Contracting State may provide for procedures to the effect that payments of income subject under this Agreement to no tax or only to reduced tax in the Contracting State in which the income arises may be made without deduction of tax or with deduction of tax only at the rate provided in the relevant Article of the Agreement.

(4) The Contracting State in which the items of income arise may require the taxpayer to provide certification of his residence in the other Contracting State issued by the competent authority of that other Contracting State.

(5) The competent authorities of the Contracting States may determine the mode of implementation of this Article by mutual agreement in accordance with the domestic law of each Contracting State.