Article 1
People Included
This Convention applies to persons who are residents of one or both of the Contracting States.
Website Last updated:
June 26, 2026
Desiring to promote their mutual economic relations by the conclusion between them of an Agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and capital.
They have agreed as follows:
Contents
CHAPTER I - SCOPE OF THE AGREEMENT
Article 1 - People Included
Article 2 - Taxes Included
CHAPTER II - DEFINITIONS
Article 3 - General Definitions
Article 4 - Resident
Article 5 - Permanent Establishment
Article 6 - Real Estate Income
CHAPTER III - INCOME TAXATION
Article 7 - Business Net Income
Article 8 - Maritime and Air Navigation
Article 9 - Affiliates
Article 10 - Dividends
Article 11 - Interest
Article 12 - Royalties and Fees for Technical Services
Article 13 - Capital Gains
Article 14 - Income from Employment
Article 15 - Directors Fees
Article 16 - Artists and Athletes
Article 17 - Pensions
Article 18 - Government Service
Article 19 - Students
Article 20 - Other Income
CHAPTER IV - TAXATION OF ASSETS
Article 21 - Capital
CHAPTER V - METHODS TO ELIMINATE DOUBLE TAXATION
Article 22 - Elimination of Double Taxation
CHAPTER VI - SPECIAL PROVISIONS
Article 23 - Non Discrimination
Article 24 - Mutual Agreement Procedure
Article 25 - Exchange of Information
Article 26 - Miscellaneous Rules
Article 27 - Members of Diplomatic Missions and Consular Offices
CHAPTER VII - FINAL PROVISIONS
Article 28 - Entry into Force
Article 29 - Termination
Protocol
This Convention applies to persons who are residents of one or both of the Contracting States.