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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.


Application of the Convention in Certain Cases

(1) This Convention is not to be interpreted as if it hindered a Contracting State from applying its domestic provisions of law for the prevention of tax evasion or tax fraud.

(2) If the provisions of paragraph (1) lead to double taxation, the competent authorities will consult with each other as set forth in paragraph (3) of Article 25 to determine how to avoid double taxation.