Permanent establishment tax: limited source taxation on dividend-equivalent profits and attributable interest with treaty rate caps.

The Article permits source taxation of a resident company's business profits in the other State only to the extent those profits represent a dividend equivalent amount or excess interest deductible in that State attributable to a permanent establishment or taxable under provisions for immovable property, royalties and gains; such taxation is limited by treaty rate ceilings. Reciprocal higher rate exposure for resident companies and a bank-specific rule for interest paid by permanent establishments are also provided.

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