background image
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.


Miscellaneous Provisions

(1) Nothing in this Agreement shall prevent the application of domestic law of any of the Contracting State in relation to taxation of the income, profits, dividends, profits or remittances from investment institutions or funds of any kind, including investment funds and pensions or its participants, who are residents of the other Contracting State provided that such income is not subject to taxation in accordance with the provisions of this Agreement.

(2) Whereas the main objective of this Agreement is to avoid double taxation, the Contracting States agree that in the event that the provisions of the Agreement shall be used in ways that give benefits not covered nor intended by it, the competent authorities of the Contracting State shall in accordance to the mutual agreement procedure of Article 25, recommends specific amendments to the Agreement. The Contracting State also agrees that any of these recommendations shall be considered and discussed in an expeditious manner with a view to amending the Agreement on the extent necessary.