Bilateral tax treaty sets PE rules, withholding caps for dividends/interest/royalties, exchange of information and anti abuse test. The Agreement establishes rules to avoid double taxation and prevent fiscal evasion for taxes on income by defining persons covered, taxes in scope, residency tie breakers and comprehensive definitions. It sets a broad concept of permanent establishment with attribution of business profits on an arm's length basis, prescribes source taxation and withholding caps for dividends, interest, royalties and fees for technical services, allocates capital gains, and provides relief through tax credits, a Mutual Agreement Procedure, exchange of information, assistance in collection, and an anti abuse principal purpose test.