This treaty follows the OECD standard model and, besides bringing greater security, it stipulates limits aimed at eliminating the possibilities of double taxation, even providing for deduction of taxes on income already taxed in another contracting state.
In addition, a new wording of articles 4 and 5 added to the text of this agreement, provides provisions on tax residence and permanent establishment in both countries in a clearer and more objective manner, facilitating its application.
Finally, the treaty also brings specific rules for the taxation of technical services and royalties related to trademarks and trade names.
This decree has been in effect since the date of its enactment.
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