Canada-Oman Tax Agreement Act, 2004

Based on the provided text, here is a generated summary:

The agreement defines what constitutes a permanent establishment, including places of management, branches, offices, factories, workshops, and mines. It also outlines specific activities that do not constitute a permanent establishment, such as the use of facilities solely for storage or display, maintenance of a stock of goods or merchandise for processing by another enterprise, or carrying on business through a broker or agent of an independent status.

The agreement further stipulates that income derived from immovable property situated in one Contracting State may be taxed in that State. It also addresses the taxation of business profits, stating that profits derived from the operation of ships or aircraft in international traffic are taxable only in the country where the ship or aircraft is registered.

Additionally, the agreement discusses associated enterprises and requires adjustments to be made when conditions between two enterprises differ from those that would be made between independent enterprises. It also addresses the taxation of dividends, stating that they may be taxed in the Contracting State where the company paying the dividends is resident, but not exceeding five percent of the gross amount if the beneficial owner is a company that controls at least ten percent of the voting power in the company paying the dividends.

Lastly, the agreement provides specific rules for shipping and air transport companies, allowing them to operate with certain tax benefits.