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 includes:

• a building site, a construction, assembly or installation project, or supervisory activities, in connection therewith, but only where the site, project or activities continue for a period more than six months;

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

Dividends