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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.


Assistance in the Collection of Taxes

(1) Each of the territories shall endeavor to collect, as if it were its own tax, any tax referred to in Article 2, which has been imposed by the other territory and the collection of which is necessary to ensure that any exemption or reduction of tax granted under this Agreement by that other territory shall not be enjoyed by persons not entitled to such benefits.

(2) In no case shall the provisions of this Article be construed so as to impose on a territory the obligation:

  • (a) to carry out administrative measures at variance with the laws and administrative practice of that or of the other territory;
  • (b) to carry out measures which would be contrary to public policy (ordre public);
  • (c) to provide assistance if the other territory has not pursued all reasonable measures of collection or conservancy, as the case may be, available under its laws or administrative practice;
  • (d) to provide assistance in those cases where the administrative burden for that territory is clearly disproportionate to the benefit to be derived by the other territory.