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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.


[Income from Securities]

A company of a Contracting State, may not be subject, in the territory of the other Contracting State, to payment of tax on distributions of income from movable securities and similar income (income from shares, founders' shares, interest and partnership shares), that it carries out merely by reason of its participation in the management or the capital of companies domiciled in that other State or because of any other relation with the companies, but the earnings distributed by these last mentioned companies, that are liable to tax shall, where applicable, be increased by adding any profits or benefits that the company of the first mentioned State would have indirectly derived from the said companies either by way of increase or decrease of the purchase price or sale price or by any other means.