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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.

ARTICLE 25

Miscellaneous Provisions

(1) No provision of the Convention, except for the Article 24, shall apply to:

  • (a) to the income which is exempt from taxation in the Contracting State in which the beneficial owner of the income is a resident, or to the income obtained by such resident which is taxable in that Contracting State to a rate lesser than that applicable to the same income obtained by other residents of this Contracting State who do not benefit from that exemption or rate;
  • (b) income obtained by a beneficial owner who is a resident of a Contracting State, and who enjoys a deduction, restoration or other permission or advantage, which is directly or indirectly associated with such income, which is not a loan granted against foreign taxes that have been paid and which is not granted to other residents of that Contracting State.

(2) The competent authorities of the Contracting State shall mutually consult each other with regard to the application of this Article.