Double taxation agreement amendment expands permanent establishment rules and caps withholding taxes while strengthening information exchange. Protocol amends the India-Poland tax treaty by specifying covered taxes, updating territorial and fiscal definitions, and redefining residence. It expands permanent establishment to include service provision by personnel exceeding an aggregate short term period, restates associated enterprises/transfer pricing adjustment rules, caps source state taxation on dividends, interest and royalties for beneficial owners, authorises taxation of gains on shares of property rich companies by the State of immovable property, and strengthens exchange of information, collection assistance and a limitation of benefits anti abuse rule.
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Double taxation agreement amendment expands permanent establishment rules and caps withholding taxes while strengthening information exchange.
Protocol amends the India-Poland tax treaty by specifying covered taxes, updating territorial and fiscal definitions, and redefining residence. It expands permanent establishment to include service provision by personnel exceeding an aggregate short term period, restates associated enterprises/transfer pricing adjustment rules, caps source state taxation on dividends, interest and royalties for beneficial owners, authorises taxation of gains on shares of property rich companies by the State of immovable property, and strengthens exchange of information, collection assistance and a limitation of benefits anti abuse rule.
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