<h1>Avoidance of double taxation enables source-based PE taxation and enhanced information exchange under the new bilateral tax treaty.</h1> The bilateral agreement allocates taxation of business profits to the source state when an enterprise's activities constitute a permanent establishment, defines specified PE categories, and incorporates an Article on Associated Enterprises to expand access to the Mutual Agreement Procedure for transfer pricing adjustments. It also provides that dividends, interest, and royalties and fees for technical services may be taxed in both residence and source states; establishes reduced withholding regimes to promote investment; creates an international-standard exchange of information framework including banking information and sharing with other agencies with consent; and includes provisions for assistance in tax collection and a limitation of benefits anti-abuse rule.