[Provisional translation]
1．Taxation on Profits from Business Activities
Where an enterprise has a permanent establishment (such as a branch, including the furnishing of services by an enterprise through personnel over a certain period of time) and carries on business in a partner country, only the profits resulting from the business carried out through the permanent establishment may be taxed in the partner country.
2．Reduction of Taxation on Investment Income
Taxation on investment income (dividends, interest and royalties) in the source country is reduced as follows:
| Dividends | Interest | Royalties | |
|---|---|---|---|
| Between parent and subsidiary companies (shareholding requirement) |
Others | ||
| 5％（at least 10%） | 10％ | Exemption (received by Governments, financial institutions, etc.) 10％（others） |
5％ |
3. Mutual Agreement Procedure
Taxation not in accordance with the provisions of the Agreement may be resolved by mutual agreement between the tax authorities of the two countries upon request by the taxpayer.
4. Exchange of Information
The Agreement enables the tax authorities of the two countries to exchange information concerning all national and local taxes of the two countries.
5. Others
The Agreement also includes the provisions on:
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(1) the corresponding adjustment for transfer pricing taxation;
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(2) the taxation on income derived in respect of a silent partnership contract; and
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(3) the prevention of abuse of the Agreement.