Procedural Rules for Taxation at Source
(1) If in the sovereign territory of a Contracting Party the taxes on dividends, interest, royalties or other items of income derived by a person who is a resident of the sovereign territory of the other Contracting Party are levied by withholding at source, the right of the first-mentioned Contracting Party 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 by this Agreement or ceases to apply.
(2) Refund applications must be submitted by the end of the fourth year following the calendar year in which the withholding tax was applied to the dividends, interest, royalties or other items of income.
(3) Notwithstanding paragraph (1), each Contracting Party shall provide for procedures to the effect that payments of income subject under this Agreement to no tax or only to reduced tax in the state of source may be made without deduction of tax or with deduction of tax only at the rate provided in the relevant Article.
(4) The Contracting Party in whose sovereign territory the items of income arise may ask for a certificate by the competent authority on the residence in the sovereign territory of the other Contracting Party.
(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.