Withholding tax reduction to lower ceilings for cross border dividends, interest, royalties and technical fees under amended treaty. The Protocol reduces withholding tax ceilings to ten percent for dividends, interest, royalties and technical fees, replaces the Exchange of Information provision with expansive information exchange obligations (including information held by financial institutions) subject to confidentiality and public policy exceptions, introduces mutual Assistance in the Collection of Taxes permitting collection and conservancy of revenue claims under the requested State's laws, and inserts a Limitation of Benefits anti abuse rule disallowing treaty benefits where obtaining them is a main purpose or where entities lack bona fide activities.