Double taxation prevention: treaty defines residency, permanent establishment, business profits and treats zakat as a tax. The Protocol clarifies key treaty definitions and operational rules: it expands person and resident definitions (including specified government entities, certain Saudi-resident Indian individuals, and tax-exempt legal persons), defines fiscal years, and treats Zakat as a tax on income. It narrows the taxable scope of business profits from exports and construction contracts to amounts attributable to a permanent establishment in the other State, includes sales outlets and agricultural sites within Permanent Establishment, and preserves domestic-law limits on expense deductions while providing for information exchange and potential mutual assistance in tax collection.
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 prevention: treaty defines residency, permanent establishment, business profits and treats zakat as a tax.
The Protocol clarifies key treaty definitions and operational rules: it expands person and resident definitions (including specified government entities, certain Saudi-resident Indian individuals, and tax-exempt legal persons), defines fiscal years, and treats Zakat as a tax on income. It narrows the taxable scope of business profits from exports and construction contracts to amounts attributable to a permanent establishment in the other State, includes sales outlets and agricultural sites within Permanent Establishment, and preserves domestic-law limits on expense deductions while providing for information exchange and potential mutual assistance in tax collection.
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