ARTICLE 28B
Assistance in the Collection of Taxes
1. The Contracting States shall lend assistance to each other in the collection of revenue claims
in respect of taxes covered by the Convention. This assistance is not restricted by Article 1.
The competent authorities of the Contracting States may by mutual agreement settle the
mode of application of this Article.
3. When a revenue claim of a Contracting State is enforceable under the laws of that State and
is owed by a person who, at that time, cannot, under the laws of that State, prevent its
collection, that revenue claim shall, at the request of the competent authority of that State, be
accepted for purposes of collection by the competent authority of the other Contracting State.
That revenue claim shall be collected by that other State in accordance with the provisions of
its laws applicable to the enforcement and collection of its own taxes as if the revenue claim
were a revenue claim of that other State.
4. When a revenue claim of a Contracting State is a claim in respect of which that State may,
under its law, take measures of conservancy with a view to ensure its collection, that revenue
claim shall, at the request of the competent authority of that State, be accepted for purposes
of taking measures of conservancy by the competent authority of the other Contracting State.
That other State shall take measures of conservancy in respect of that revenue claim in
accordance with the provisions of its laws as if the revenue claim were a revenue claim of
that other State even if, at the time when such measures are applied, the revenue claim is not
enforceable in the first-mentioned State or is owed by a person who has a right to prevent its
collection.
5. When a Contracting State may, under its law, take interim measures of conservancy by
freezing of assets before a revenue claim is raised against a person, the competent authority
of the other Contracting State, if requested by the competent authority of the first mentioned
State, shall take measures for freezing the assets of that person in that Contracting State in
accordance with the provisions of its law.
6. Notwithstanding the provisions of paragraphs 3 and 4, a revenue claim accepted by a
Contracting State for purposes of paragraph 3 or 4 shall not, in that State, be subject to the
time limits or accorded any priority applicable to a revenue claim under the laws of that State
by reason of its nature as such. In addition, a revenue claim accepted by a Contracting State
for the purposes of paragraph 3 or 4 shall not, in that State, have any priority applicable to
that revenue claim under the laws of the other Contracting State.
7. Proceedings with respect to the existence, validity or the amount of a revenue claim of a
Contracting State shall not be brought before the courts or administrative bodies of the other
Contracting State.
8. Where, at any time after a request has been made by a Contracting State under paragraph 3
or 4 and before the other Contracting State has collected and remitted the relevant revenue
claim to the first-mentioned State, the relevant revenue claim ceases to be:
a) in the case of a request under paragraph 3, a revenue claim of the first-mentioned
State that is enforceable under the laws of that State and is owed by a person who, at
that time, cannot, under the laws of that State, prevent its collection, or
9. In no case shall the provisions of this Article be construed so as to impose on a Contracting
State the obligation:
a) to carry out administrative measures at variance with the laws and administrative
practice of that or of the other Contracting State;
b) to carry out measures which would be contrary to public policy;
c) to provide assistance if the other Contracting State has not pursued all reasonable
measures of collection or conservancy, as the case may be, available under its laws or
administrative practice;
d) to provide assistance in those cases where the administrative burden for that State is
clearly disproportionate to the benefit to be derived by the other
Contracting State.”