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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.



(1) Where, as a result of the controls carried out by the competent tax authorities, some adjustments are made on the amount of profits earned in a fiscal year, resulting in the modification of the proportion defined in paragraph (4) of Article 10, then these adjustments shall be taken into account for the apportionment, between the two Contracting States, of the taxation bases pertaining to the financial year during which the adjustments took place.

(2) The adjustments relating to the amount of income to be apportioned but not affecting the ratio of profits realized which have been taken into account for the apportionment of income which is the subject of such adjustments, shall give rise, according to the rules applicable in each State, to a supplementary tax apportioned in the same proportion as the initial tax.