Double taxation relief: credit for partnership income, apportionment for insurance permanent establishments, and reservation on collection assistance. A resident of Ireland who is a partner in an India-resident partnership remains liable in Ireland on the partner's share; that share is treated as Indian-source income and the appropriate part of Indian tax borne by the partnership is creditable in Ireland. Profits attributable to insurance permanent establishments may be determined by apportionment of enterprise profits if the method accords with Article 7 principles. India may tax an Irish company's permanent establishment at a higher rate than a similar Indian company. Ireland's laws then precluded collection assistance but could prompt negotiations if changed.
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.
Double taxation relief: credit for partnership income, apportionment for insurance permanent establishments, and reservation on collection assistance.
A resident of Ireland who is a partner in an India-resident partnership remains liable in Ireland on the partner's share; that share is treated as Indian-source income and the appropriate part of Indian tax borne by the partnership is creditable in Ireland. Profits attributable to insurance permanent establishments may be determined by apportionment of enterprise profits if the method accords with Article 7 principles. India may tax an Irish company's permanent establishment at a higher rate than a similar Indian company. Ireland's laws then precluded collection assistance but could prompt negotiations if changed.
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