Artificial avoidance of permanent establishment recognized in multiple tax treaties via notification of Article 5 agency provisions. India notifies, under the BEPS Convention, that certain bilateral tax agreements contain provisions corresponding to Article 12(3)(a) and Article 12(3)(b) designed to prevent artificial avoidance of permanent establishment status through agency, commissionnaire, or similar arrangements, specifying each contracting jurisdiction and the relevant Article 5 paragraph in those treaties.
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.
Artificial avoidance of permanent establishment recognized in multiple tax treaties via notification of Article 5 agency provisions.
India notifies, under the BEPS Convention, that certain bilateral tax agreements contain provisions corresponding to Article 12(3)(a) and Article 12(3)(b) designed to prevent artificial avoidance of permanent establishment status through agency, commissionnaire, or similar arrangements, specifying each contracting jurisdiction and the relevant Article 5 paragraph in those treaties.
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