Artikel VIII

Each Contracting State shall endeavour to establish procedures to enable taxpayers to receive income dealt with under articles 11 and 12 without the imposition of withholding taxes where the Agreement provides for taxation in the State of residence only. Where the Agreement provides for taxation in the State where the income arises each State shall endeavour to establish procedures to enable taxpayers to receive income under deduction of tax at the rate provided for in the Agreement.
Where tax has been levied at source at a rate in excess of that provided for under the terms of the Agreement, applications for the refund of the excess amount of tax have to be lodged with the competent authority of the State having levied the tax, within a period of two years after the expiration of the calendar year in which the tax has been levied. Where a claim is made by a taxpayer for a refund as meant in the foregoing sentence tax withheld at source in a Contracting State at the rate in excess of that provided for under the terms of the Agreement will be refunded in a timely manner.