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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.


[Registration Duties]

(1) Where a deed or a judgment established in one of the Contracting States is presented for registration in the other Contracting State, the duties applicable in this last-mentioned State shall be determined as per the rules provided by its domestic laws, except, if necessary, in the case of deduction, of the registration duties which were levied in the first-mentioned State, from the duties owed in the other State.

(2) However, deeds or judgments pertaining to the transfer of property, usufruct of immovable property or of goodwill, those pertaining to the transfer of the use of immovable property and deeds or judgments stating a transfer of right to a lease or profit from a lease pledge pertaining to the whole or part of an immovable property, may be subjected to a transfer duty only in the Contracting State on whose territory this immovable property or business assets are situated.

(3) The provisions of the first sub paragraph of this Article shall not be applicable to the title deeds of companies or to the modifications of the Articles of Association. These deeds shall give rise to the levy of ad valorem duty only in the State where the statutory head office of the company is situated. If it is a question of a merger or a similar business operation, the levy shall be carried out in the State where the headquarters of the parent (absorbing) company or the new company are situated.