Source-based taxation and anti-abuse rules permit source-state taxation and cap withholding on dividends, interest and royalties. Revised bilateral agreement introduces anti-abuse provisions and permits source-based taxation of capital gains on alienation of shares; limits treaty benefits to genuine residents; allows source-state taxation of business profits where a permanent establishment exists; taxes construction projects continuing 270 days or more and services continuing more than 183 days in any 12 month period; leaves shipping and aircraft profits taxable in the resident state; and sets maximum source-state withholding limits on dividends (with a reduced rate when the beneficial owner holds at least a 10% equity interest) and on interest and royalties.