The Protocol amends the Convention in order to bring its provisions into line with the OECD Model Tax Convention on Income and on Capital and the latest OECD standards.
The document provides, in particular, for an increase in the general tax rate on dividends from 10% to 15% and interest from 2% to 5%. Royalty tax rates were also increased: from 0% to 5% for the use of any copyright in scientific works, patents, etc., and from 5% to 10% for the use of copyright in literary works or works of art.
In addition to the increase in rates, the Convention is to be supplemented with new articles on limiting the application of the Convention's preferential provisions if the main purpose is to obtain such benefits and on enhancing the capacity of the competent authorities of the Contracting States to exchange tax information.
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