The maximum rates of withholding tax are: -   5% on dividends (no withholding tax on dividends paid to the government or to public facilities); -   5% on interest (no withholding tax on interest in the public sector and in connection with loans granted by a public institution for the purpose of export promotion); and -   10% on royalties (including product leasing). Deviations from the OECD Model include that: -   a building site, a construction, assembly or installation project, or supervisory activities, in connection therewith, constitutes a permanent establishment only if it lasts more than 6 months....