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CHAPTER I - Income Tax
CHAPTER II - Registration Fees and Stamp Duties
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.


[Apportionment of Assessments]

(1) The apportionment of the taxation bases referred to in Article 14 of this Convention shall be carried out by the company and notified by it to each of the competent fiscal administrative bodies, within the time limits granted to it by the laws of each State for declaring the distributions of taxable income, to be carried out by the company.

(2) In support of this apportionment, the company shall supply to each of the said administrative bodies, other than the documents that it is supposed to produce or deposit by virtue of the domestic laws, a copy of these earnings or deposits before the administrative bodies of the other State.

(3) Any difficulties or disputes arising on the subject of apportionment of the taxation bases shall be resolved by a mutual Agreement between the competent fiscal administrative bodies. If there is no such accord, the dispute shall be settled by a mixed commission provided for under Article 33 of this Convention.