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Brief
This treaty between two countries sets rules for taxation on income earned by individuals and businesses in each other's territories. The key points are:
- Taxation on business profits: Profits from a business in one country can be taxed only in that country, unless the business has a permanent establishment (a fixed place of business) in the other country.
- Income from immovable property: Income from property, such as rent or sale of land and buildings, is taxable where the property is located.
- Shipping and air transport: Profits from international shipping and air transport are generally taxable only in the country where the enterprise is based, unless the profits are earned on a voyage that starts and ends in the other country.
- Associated enterprises: If two companies or individuals have close ties (management, control, capital) between them, income that would normally go to one of them but doesn't because of their connection can be taxed to both.
- Dividends: Companies can tax dividends paid out as long as they're not more than 5% of the gross dividend amount if the recipient holds a significant stake (at least 25%) in the company paying it.
These rules aim to prevent double taxation and provide clarity on which country can tax different types of income.
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