Article 1
Persons Covered
This Agreement shall apply to persons who are residents of one or both of the Contracting States.
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June 26, 2026
Contents
CHAPTER I - SCOPE OF THE AGREEMENT
Article 1 - Persons Covered
Article 2 - Taxes Covered
CHAPTER II - DEFINITIONS
Article 3 - General Definitions
Article 4 - Resident
Article 5 - Permanent Establishment
CHAPTER III - TAXATION OF INCOME
Article 6 - Income from Immovable Property
Article 7 - Business Profits
Article 8 - Shipping and Air Transport
Article 9 - Associated Enterprises
Article 10 - Dividends
Article 11 - Interest
Article 12 - Royalties
Article 13 - Capital Gains
Article 14 - Independent Personal Services
Article 15 - Income from Employment
Article 16 - Directors' Fees
Article 17 - Entertainers and Sportspersons
Article 18 - Pensions, Annuities and Social Security Payments
Article 19 - Government Service
Article 20 - Professors and Researchers
Article 21 - Students and Apprentices
Article 22 - Other Income
CHAPTER IV - METHODS FOR THE ELIMINATION OF DOUBLE TAXATION
Article 23 - Elimination of Double Taxation
CHAPTER V - SPECIAL PROVISIONS
Article 24 - Non-Discrimination
Article 25 - Mutual Agreement Procedure
Article 26 - Exchange of Information
Article 27 - Assistance in the Collection of Taxes
Article 28 - Members of Diplomatic Missions and Consular Posts
Article 29 - Protocol
CHAPTER VI - FINAL PROVISIONS
Article 30 - Entry Into Force
Article 31 - Termination
Protocol
This Agreement shall apply to persons who are residents of one or both of the Contracting States.