- Taxation on Profits from Business Activities
Where an enterprise has a permanent establishment (branch, etc.) and conducts business activities in a partner country, only the profits resulting from the business activities carried out through the permanent establishment may be taxed in the country where the permanent establishment is situated.
- 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
Others ５％（at least 10%） 10％ Exemption (received by Governments, etc.)
- 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.
- 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.
The Agreement also includes the provisions on:
(1) the appropriate adjustment for transfer pricing taxation;
(2) taxation on income derived by a silent partner in respect of a silent partnership contract; and
(3) prevention of abuse of the Agreement.