Dividend taxation principles limit source-state withholding where corporate beneficial ownership secures reduced relief and credit mechanisms. The Protocol revises treaty rules on allocation and source taxation by: allowing permanent establishments deductions for business expenses subject to host-State limitations and a fallback deduction cap where domestic law disallows such deductions; disallowing certain payments from a permanent establishment to head office (royalties, commissions, management fees and, except for banks, interest) except reimbursements; imposing reduced source-state taxation on shipping income, dividends, interest, and royalties/technical fees with specified caps and definitions; and taxing independent personal services in the source State when presence exceeds the 183-day threshold or a fixed base exists, while adjusting foreign tax credit computation and specifying entry into force and application rules.