Refund of Withholding Tax. 1. If in one of the Contracting States the taxes on dividends, interest, royalties, or other items of income are levied by withholding at source, then the right to apply the withholding of tax at the rate provided for under the domestic law of that State is not affected by the provisions of this Convention. 2. The tax so withheld at source shall be refunded on application to the extent that its levying is limited by this Convention. 3. The period for application for a refund is four years from the end of the calendar year in which the dividends, interest, royalties, or other items of income have been received. 4. The Contracting State in which the income arises may require an administrative certification by the Contracting State of which the taxpayer is a resident, with respect to the fulfillment of the conditions for the unlimited tax liability in that State. 5. The competent authorities of the Contracting States shall implement the foregoing provisions by mutual agreement pursuant to Article 25 (Mutual Agreement Procedure). 6. The competent authorities of the Contracting States may establish by mutual agreement other procedures for the implementation of tax reductions provided under this Convention.
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Samples: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
