As expected, the new tax treaty is broadly in line with the most recent OECD Model Tax Convention and notably includes a "property-rich clause" as well as a principal purpose test provision. It also narrows the circumstances in which withholding will be required from payments of dividends and interest and (through the Protocol) provides additional details on the types of investment vehicles that will be regarded as residents.

The treaty must be ratified by each country before it can come into force and is expected to have effect in 2023.

For the full text of the treaty please, click here.