Capital gains taxation change: shares acquired after protocol taxable in company residence, with transitional reduced rate and anti-abuse limits. The Protocol expands Permanent Establishment to include prolonged service furnishing through personnel, revises interest taxation to permit source State tax and provides an exemption for bank interest subject to an effective date limitation, introduces Article 12A allowing source and residence taxation of Fees for Technical Services with a withholding cap and PE/fixed base exceptions, amends Capital Gains rules to permit taxation by the company's State of residence for shares acquired after the specified date with transitional rate relief, strengthens exchange of information and adds assistance in collection and limitation of benefits rules with operational thresholds and exceptions.