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. The term “permanent establishment” also encompasses:

• a building site, a construction, assembly or installation project or any supervisory activity in connection with such site or project, but only where such site, project or activity continues for a period or periods aggregating more than six months within any 12 month period; and

• the furnishing of services, including consultancy services, by an enterprise through employees or other personnel engaged by the enterprise for this purpose, but only if the activities of that nature continue (for the same or a connected project) within a contracting state for period or periods aggregating more than six months within any 12 month period.

Dividends