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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.

ARTICLE 15

[Earnings and Adjustments]

(1) Where, following the audit controls on the amount of profits accrued in the course of an accounting period, carried out by the competent fiscal administrative bodies, any adjustments/rectifications are carried out, which result in the modification of the proportion defined in paragraph (2) of Article 14 of this Convention, then these rectifications shall be taken into account for the apportionment, between the two Contracting States, of the taxation bases pertaining to the accounting period during which these adjustments took place.

(2) Adjustments concerning the amount of income to be apportioned, not affecting the proportion of accrued profits, which were taken into account for the apportionment of the income, being the subject of the said adjustments, shall give rise, as per the applicable rules in each State, to an additional taxation apportioned in the same proportion as the initial taxation.