1. Taxation on Business ProfitsWhere an enterprise of one of the two countries has in the other country a permanent establishment (such as a branch) through which the enterprise carries on business, only the profits attributable to the permanent establishment may be taxed in that other country. The profits attributable to a permanent establishment will be calculated by comprehensively recognizing internal dealings between its head office and branches and by strictly applying the arm’s length principle.
2. Taxation on Investment IncomeTaxation on investment income (dividends, interest and royalties) in the source country will be subjected to the reduced maximum rates or exempted as follows:
|Existing Convention||New Convention|
|Dividends||15％||５％（holding at least 25％ of the voting power for 365 days）|
|Interest||Exempted（received by the Governments, etc.）|
|Exempted（received by the Governments, etc.）|