The maximum withholding taxes are: -   15% on dividends, in general, and 0% on dividends in respect of a shareholding of 10% in the distributing company (the press release does not indicate whether the 10% refers to the capital or to the voting rights in the distributing company – in the existing treaty the threshold is 25% of the voting power); -   0% on interest; and -   0% on royalties. Following the OECD Model Convention, building sites, and construction or installation projects constitute a permanent establishment if they last more than 12 months. The new treaty modifies...