Tax treaty provision: automatic alignment of Permanent Establishment rules and preservation of land value increment tax treatment. The Protocol provides that more beneficial domestic law governs for residents of the other territory where applicable, preserves imposition of the Land Value Increment Tax under the Land Tax Act and bars its deduction from the income tax of residents in the other territory, establishes automatic mirror revisions to certain Permanent Establishment provisions to follow specific changes in the India-People's Republic of China treaty (including omission of 'or delivery' and insertion of a dependent agent/stock and delivery clause), and confirms that domestic laws govern taxation except where the Agreement provides otherwise, with double taxation relief accorded under the Agreement's Article on relief.
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.
Tax treaty provision: automatic alignment of Permanent Establishment rules and preservation of land value increment tax treatment.
The Protocol provides that more beneficial domestic law governs for residents of the other territory where applicable, preserves imposition of the Land Value Increment Tax under the Land Tax Act and bars its deduction from the income tax of residents in the other territory, establishes automatic mirror revisions to certain Permanent Establishment provisions to follow specific changes in the India-People's Republic of China treaty (including omission of "or delivery" and insertion of a dependent agent/stock and delivery clause), and confirms that domestic laws govern taxation except where the Agreement provides otherwise, with double taxation relief accorded under the Agreement's Article on relief.
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