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The Double Taxation Treaty between the two countries defines permanent establishment as a fixed place of business through which an enterprise carries on its activities. This includes buildings or construction sites, installations, drilling rigs, ships, and other equipment used for natural resource exploration or exploitation. The treaty also outlines conditions under which income from immovable property, business profits, shipping and air transport, associated enterprises, dividends, interest, royalties, and capital gains may be taxed in one or both countries.
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