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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.


Entry into Force

(1) This Agreement shall enter into force on the first day of the third month after each Contracting Party has notified the other in writing, through diplomatic channels, that the internal procedures required by that Party for the entry into force of the Agreement have been complied with.

(2) Upon entry into force, this Agreement shall have effect:

  • (a) for tax matters involving intentional conduct which is liable to prosecution under the criminal laws of the requesting party (irrespective of whether contained in the tax laws, the criminal code or other statutes), on that date, and
  • (b) for all other matters covered in Article 1, on that date, but only in respect of taxable periods beginning on or after that date, or where there is no taxable period, all charges to tax arising on or after that date.