The 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.

A building site or construction or installation project constitutes a permanent establishment only if it lasts more than 12 months.

Dividends

The term “dividends” means income from shares, jouissance shares or jouissance rights, mining shares, founders shares or other rights, not being debt-claims, participating in profits, as well as income which is subjected to the same taxation treatment as income from shares by the tax legislation of the state of which the paying company is a resident.

Dividends paid by a company which is a resident of a contracting state to a resident of the other contracting state may be taxed in that other state.