Exchange of information expanded to require broader cross-border tax data sharing while preserving confidentiality protections.

Amendments revise resident status criteria, allow deductions for permanent establishment business expenses under the taxing State's law, cap source-State dividend tax where recipient is beneficial owner, reallocate capital gains taxing rights for shares linked to immovable property or resident companies, exempt governmental income from tax in the other Contracting State, modify nondiscrimination treatment of permanent establishments, introduce a Limitation of Benefits denying treaty advantages to entities formed to obtain them, and expand Exchange of Information obligations including confidentiality and duties to obtain requested information even when not needed domestically.

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