Article 5 of the Protocol is the same as the corresponding provision in the protocol to…

prior Convention. It confirms Italy’s practice of granting reduced rates of tax in a treaty by initially withholding tax at the statutory rate and providing refunds of the excess over the treaty rate on the basis of an official certification that the claimant is a resident of the treaty country entitled to such benefits. The claim for refund must be made within the time limit fixed by the

law of the State that is obliged to make the refund. This article simply confirms Italy’s existing practice. It does not prevent either Contracting State from changing its method of implementing Convention benefits.