Conduit arrangement rules restrict treaty benefits where income is routed to non-residents; lower source-tax rates may apply. The Protocol treats recognised pension funds as treaty residents, refines permanent establishment rules including taxation of service remuneration and contractual profits attributable to the PE, and limits PE creation by mere stock or delivery facilities. It denies Articles 10-12 and 22 benefits for conduit arrangements designed to route income to non residents, provides for application of lower source tax rates granted by later OECD member State treaties, clarifies taxation of gains from alienation under Articles 7, 12 and 13, permits limited differential PE tax rates, and sets procedural safeguards and scope for exchange of information and mutual agreement implementation.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Conduit arrangement rules restrict treaty benefits where income is routed to non-residents; lower source-tax rates may apply.
The Protocol treats recognised pension funds as treaty residents, refines permanent establishment rules including taxation of service remuneration and contractual profits attributable to the PE, and limits PE creation by mere stock or delivery facilities. It denies Articles 10-12 and 22 benefits for conduit arrangements designed to route income to non residents, provides for application of lower source tax rates granted by later OECD member State treaties, clarifies taxation of gains from alienation under Articles 7, 12 and 13, permits limited differential PE tax rates, and sets procedural safeguards and scope for exchange of information and mutual agreement implementation.
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