The maximum rates of withholding tax are: -   10% on dividends; -   10% on interest, subject to exceptions;     10% on royalties. Deviations from the OECD Model include that: -   the term "permanent establishment" includes (i) a building site or construction, assembly or installation project if it lasts more than 6 months, (ii) supervisory activities carried on for more than 6 months in connection with a building site or construction, assembly or installation project, and (iii) the furnishing of services, including consultancy services, through employees or other personnel engaged by the enterprise for such purpose, but...