»Ê¹ÚÌåÓýapp

»Ê¹ÚÌåÓýapp agreement that entered into force in 2018 replaced that which had been in effect since 1998. Apart from a general updating to reflect changes in the OECD Model Tax Convention and the domestic laws and treaty preferences of both states, notable changes include:

Permanent Establishment (Article 5)

»Ê¹ÚÌåÓýappre is an expanded definition of ‘permanent establishmentâ€�, including the circumstances in which the provision of services will create a permanent establishment. »Ê¹ÚÌåÓýappse changes broadly accommodate changes to other articles of the 1997 DTC.

Management & Technical Fees Article (Article 13 in the 1997 DTC)

Article 13 of the 1997 DTC, which permitted gross taxation of management and technical fees, is not replicated in the 2018 DTA.

Mutual Agreement Procedure (Article 24)

»Ê¹ÚÌåÓýapp 2018 DTA includes an arbitration provision based on the OECD Model Tax Convention. »Ê¹ÚÌåÓýappre was no such provision in the 1997 DTC.

Administrative issues

»Ê¹ÚÌåÓýapp Exchange of information article (Article 25) was updated to follow the latest OECD Model article. In addition, an article providing for Assistance in the Collection of Taxes (Article 26) is included in the 2018 DTA. »Ê¹ÚÌåÓýappre was no such provision in the 1997 DTC.