Bilateral tax treaty and protocol enter into force, preventing double taxation and setting withholding limits and anti-abuse rules

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Full Text of the Document

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....The government notified entry into force of a bilateral agreement and protocol between the two Contracting States to avoid double taxation and prevent fiscal evasion, effective for income arising from the first day of the fiscal year following entry into force. The treaty covers taxes on income, defines residency, permanent establishment rules, and allocation of taxing rights; prescribes withholding limits (dividends 5%/10%, interest 10%, royalties/technical fees 10%), rules on business profits, capital gains, employment income, and exemptions for certain persons. It includes provisions on non-discrimination, mutual agreement procedure, exchange of information, assistance in collection, a principal-purpose anti-abuse rule, and termination mechanics.....