The DTT will come into effect on 1st January following the year in which the parties exchange notifications of ratification.
The most important provisions of the treaty are as follows:
A building site or construction or installation project or any supervisory activities in connection with such site or project constitutes a permanent establishment only if it lasts more than 12 months.
In cases where the beneficial owner holds at least 20% of the capital of the company paying the dividend or has invested an amount of at least €100,000 in the acquisition of the shares or other rights of the company, the withholding tax rate is set at 5%. In all other cases the withholding tax rate is 15%.
The withholding tax rate on interest is 2%.
The withholding tax rate on royalties in respect of any copyright of scientific work, patents, trademarks, secret formula, process or information concerning industrial, commercial or scientific experience is 5% (10% in all other cases).
Capital gains arising from a disposal of shares or any other movable property are granted to the country in which the person making the disposal is a tax resident.