Withholding tax caps on cross-border dividends, interest and royalties reduced under amended DTAA, limiting source taxation.

Profit attribution to a permanent establishment is limited to remuneration attributable to its actual activities; head office profits remain taxable in the resident State. The Protocol ties shipping profit methods to the Indian statutory percentage at signature and provides that any later Indian statutory reductions reduce the Convention percentage proportionately. It mandates refund procedures for excess source taxation, and requires that more favourable source tax limits India grants in later OECD member treaties on dividends, interest, royalties or fees for technical services also apply under this Convention from the date those treaties enter into force.

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