Most favoured nation clause extends lower royalty and technical service tax terms from OECD treaties to this DTAA. The Protocol adds a most favoured nation rule applying more favourable royalty and fees for technical services taxation from later OECD member conventions; requires Belgium to allow deductions for executive and general administrative expenses reasonably allocable to an Indian enterprise's Belgian permanent establishment, with a floor equal to amounts allowable at signature; and mandates mutual notification and consultation between competent authorities where domestic law later amends tax credit or reduction rules, with English prevailing among authenticated language texts.
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.
Most favoured nation clause extends lower royalty and technical service tax terms from OECD treaties to this DTAA.
The Protocol adds a most favoured nation rule applying more favourable royalty and fees for technical services taxation from later OECD member conventions; requires Belgium to allow deductions for executive and general administrative expenses reasonably allocable to an Indian enterprise's Belgian permanent establishment, with a floor equal to amounts allowable at signature; and mandates mutual notification and consultation between competent authorities where domestic law later amends tax credit or reduction rules, with English prevailing among authenticated language texts.
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