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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, taxes on dividends, interest, royalties or other earnings draw by a person domiciled in the other Contracting State are collected through withholding, the right of the former state to withhold this tax at the rate provided for under domestic tax law will not be effected by this agreement. The tax collected by withholding is to be reimbursed on the request of the taxpayer if and to the extent that it is reduced or wholly removed by this Convention.

(2) Applications for reimbursement must be submitted by the end of the fourth calendar year following the assertion of withholding tax on the dividends, interest, royalties or earnings.

(3) Irrespective of Paragraph (1), each Contracting State will establish procedures under which payment of earnings that are subject to reduced or no withholding tax under this Convention, can be done without or only with the withholding tax that is provided for in the respective article.

(4) The Contracting State from which the earnings originate can demand a certification of residency in the other Contracting State from the competent authorities.

(5) The competent authorities can, in mutual agreement, decide on the implementation of this Article and if needed establish other procedures for the execution of the tax reductions or exemptions provided for in this agreement.