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.
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|
|Interest||Exempted (paid on Government bonds, etc.) 10% (others)||Exempted (paid on Government bonds, etc.) 5% (others)|
|Royalties||Exempted (copyright) 10% (others)||Exempted|