ARTICLE 27

Assistance in Collection

This article provides for mutual assistance in the collection of taxes where required to avoid an abuse of the Convention. The provision is intended merely to insure that the benefits of the Convention will only be available with respect to persons entitled to such benefits; it does not in anyway alter the rights under other provisions of the Convention.

This article provides that each State will endeavor to collect for the other State such amounts as may be necessary to insure that any exemption or reduced rate of tax granted under the Convention will not be availed of by persons not entitled to those benefits. The 1954 Convention contained a similar provision. However, under a provision not explicitly contained in the 1954 Convention (but nonetheless implied), this article does not require a State, in order to collect taxes which are imposed by the other State, to undertake any administrative measures that differ from its internal regulations or practices nor does this article require a State to undertake any administrative or judicial measures which are contrary to that State's sovereignty, security, or public policy.