The main provision of the agreement are as follows:

Permanent establishment

The term ‘permanent establishment' means a fixed place of business through which the business of an enterprise is wholly or partly carried on a building site, a construction, assembly or installation project or supervisory activities in connection therewith or drilling rig or ship used for the exploring or exploiting of natural resources constitute a permanent establishment only if such site, project or activities continue for a period of more than 12 months.

Dividends

Dividends paid by a company which is a resident of a Contracting State to a resident of the other Contracting State shall be taxable only in that other State.

Interest

Interest arising in a Contracting State and paid to a resident of the other Contracting State shall be taxable only in that other State.

Royalties