Generate professional replies, appeals, opinions to Show Cause Notices, assessment orders, audit objections, and other legal communications using TaxTMI's AI Drafter.
Permanent establishment profit allocation permits source-state taxation subject to capped additional tax under the treaty. The treaty permits source-state taxation of immovable property, capital gains from immovable property, directors' fees, and profits of construction or installation permanent establishments limited to profits attributable to the establishment; deliveries of machinery or equipment from outside the State are excluded from attribution. Administrative expenses incurred outside India are deductible under the corresponding Indian income tax provision. Dividend taxation by India is subject to a capped source withholding rate, and a most-favoured-nation rule makes lower rates or narrower scopes in OECD-member conventions applicable here for dividends, interest, royalties and fees for technical services. Source-State may impose a limited differential tax on permanent establishment profits and a capped additional tax on profits of an Indian resident company with a permanent establishment in Hungary.
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.
Permanent establishment profit allocation permits source-state taxation subject to capped additional tax under the treaty.
The treaty permits source-state taxation of immovable property, capital gains from immovable property, directors' fees, and profits of construction or installation permanent establishments limited to profits attributable to the establishment; deliveries of machinery or equipment from outside the State are excluded from attribution. Administrative expenses incurred outside India are deductible under the corresponding Indian income tax provision. Dividend taxation by India is subject to a capped source withholding rate, and a most-favoured-nation rule makes lower rates or narrower scopes in OECD-member conventions applicable here for dividends, interest, royalties and fees for technical services. Source-State may impose a limited differential tax on permanent establishment profits and a capped additional tax on profits of an Indian resident company with a permanent establishment in Hungary.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
AI Drafter - (New and Powerful) ✕
Generate professional replies, appeals, opinions to Show Cause Notices, assessment orders, audit objections, and other legal communications using TaxTMI's AI Drafter. 
of 
TaxTMI 
