- 1.Dividends, interest or royalties arising in a Contracting State and paid in respect of a holding, debt-claim, right or property which is effectively connected with a permanent establishment situated in the other Contracting State shall be taxable in the first-mentioned State in accordance with the provisions of Articles 10, 11 and 12 respectively.
- 2.The Contracting State where the permanent establishment is situated, shall eliminate double taxation in accordance with Article 21.
- 3.The provisions of paragraphs 1 and 2 shall apply wherever the head office of the enterprise on which the permanent establishment depends is situated, provided an agreement is in place between the State where the head office of the enterprise is situated and the Contracting State in which the dividends, interest or royalties arise, which includes a provision similar to Article 24 of the Convention.
- 4.The provisions of Article 27 shall apply accordingly.
