The main provisions of the agreement are:

P ermanent establishment

The term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on.

The term "permanent establishment" encompasses:

- a building site, construction, assembly or installation project or supervisory activities in connection with it, but only where such site, project or activities continue for a period of more than six months in any twelve month period;

- the furnishing of services, including consultancy services, by an enterprise through employees or other personnel engaged by the enterprise for such purpose, but only where activities of that nature continue (for the same or a connected project) within the country for a period or periods aggregating more than six months in any twelve month period.

Dividends