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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.


Reimbursement of Deductible Taxes

(1) If, in one Contracting State, taxes on dividends, interest, royalties, or other income derived by a person residing 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 forth calendar year following the assessment of the tax withholding on dividends, interest, royalties, or other income.

(3) Notwithstanding paragraph (1), every Contracting State shall establish procedures for payment of income which according to this Convention are subject to a reduced tax rate or no tax in the State in which it originates, can be made without any tax withholding or only with the tax withholding provided for in the respective Article.

(4) 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.

(5) By mutual agreement, the competent authorities can establish rules regarding the application of this Article and optionally specify other procedures for the tax benefits provided for under this Convention.