Egypt-Georgia Income Tax Treaty: effective from January 2013

Signed in Tbilisi on 25 May 2010, the Egyptian-Georgian income and capital tax treaty entered into force on 20 December 2012 and came into effect on 1 January 2013.

Its main provisions 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.

The term "permanent establishment" also includes:

• a building site, a construction, installation or assembly project or a supervisory activities in connection therewith, but only if such site, project or activities is continued for more than six months;

• any facilities and activities provided in connection with, prospecting for, or extraction, exploration or exploitation of natural resources;

• the furnishing of services, including consultancy services, by a resident of a contracting state through employees or other personnel for a period or periods aggregating more than 183 days in any twelve month period.

Dividends