Exchange of information expands mutual tax inquiries while barring fishing expeditions and requiring data accuracy and protection. The Protocol clarifies key treaty mechanics: it defines fiscal year and tax, excludes penalties from tax credit, fixes the 270 day construction period from actual construction commencement, limits Article 15 to individuals, defines India's Central Bank as the Reserve Bank of India, and sets residency for Article 21 by fiscal year of visit or the preceding fiscal year. It specifies container profits taxable only in the enterprise's State except when containers are used solely in the other State, qualifies non discrimination for permanent establishments, and prescribes detailed standards and procedures for exchange of information, cost allocation, data accuracy and protection.
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.
Exchange of information expands mutual tax inquiries while barring fishing expeditions and requiring data accuracy and protection.
The Protocol clarifies key treaty mechanics: it defines fiscal year and tax, excludes penalties from tax credit, fixes the 270 day construction period from actual construction commencement, limits Article 15 to individuals, defines India's Central Bank as the Reserve Bank of India, and sets residency for Article 21 by fiscal year of visit or the preceding fiscal year. It specifies container profits taxable only in the enterprise's State except when containers are used solely in the other State, qualifies non discrimination for permanent establishments, and prescribes detailed standards and procedures for exchange of information, cost allocation, data accuracy and protection.
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