Non-discrimination principle clarified: States may tax permanent establishment profits at a higher rate than similar domestic companies. Protocol to the India-Jordan tax convention records three interpretative understandings: Article 9's associated enterprises provision does not apply in cases of fraud or wilful default; Article 17's treatment of artistes and sportsmen applies to income from activities performed under bilateral cultural agreements; and Article 24's non-discrimination clause does not prevent a State from taxing profits of a foreign company's permanent establishment at a higher rate than those of a similar domestic company.
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.
Non-discrimination principle clarified: States may tax permanent establishment profits at a higher rate than similar domestic companies.
Protocol to the India-Jordan tax convention records three interpretative understandings: Article 9's associated enterprises provision does not apply in cases of fraud or wilful default; Article 17's treatment of artistes and sportsmen applies to income from activities performed under bilateral cultural agreements; and Article 24's non-discrimination clause does not prevent a State from taxing profits of a foreign company's permanent establishment at a higher rate than those of a similar domestic company.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 
Join Channel
TaxTMI 
