- Provisions concerning business profits resulting from business activities
When an enterprise establishes a permanent establishment (branch, etc.) in the partner country and conducts business activities, only business profits resulting from business activities carried out through the permanent establishment is to be subject to tax in the said country.
- Provisions to reduce taxation on investment income in the source country
Taxation on investment income (dividends, income from debt-claims (interest) and royalties) in the source country is reduced as follows.
Dividends Income from debt-claims (Interest) Royalties Between parent and subsidiary (Shareholding requirement) Others 5% (at least 10%) 10% Exemption (government, etc.)
5% (Use of equipment)
- Provisions concerning dispute resolution between the tax authorities of the two countries
If a taxpayer considers that any tax imposed on him/her is not in accordance with the provisions of the Convention, he/she may request for dispute resolution between the tax authorities (mutual agreement procedure).
- Provisions concerning exchange of Information between the tax authorities of the two countries
The Convention enables the tax authorities of the two countries to exchange information regarding tax matters.