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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.


Entry into Force

(1) This Convention shall be ratified; the instruments of ratification shall be exchanged at Bonn as soon as possible.

(2) This Convention shall enter into force thirty days after the date of the exchange of instruments of ratification and shall have effect in both Contracting States:

  • (a) In respect of taxes levied for the taxation period following the year in which the Convention enters into force and for subsequent taxation periods;
  • (b) In respect of taxes withheld at source on amounts paid after 31 December of the year in which the Convention enters into force.