Tax treaty – Decree on grant of benefits

On 3 October 2012, the Government issued a Decree to provide guidance for the grant of benefits under a tax treaty. To be eligible for the reduced withholding tax rate under an applicable treaty, taxpayers must submit a certificate of residence issued by the tax authorities of the other contracting (Residence) state. Unless the application of a tax treaty is disputed or unless such a certificate is submitted by the taxpayer, tax must be withheld according to the applicable domestic rates.
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