Tax Treaty Amendments expand permanent establishment rules, limit treaty benefits, cap source taxation and strengthen information exchange. The Protocol amends the India-Poland tax treaty to revise taxes covered, territorial and fiscal definitions, broaden fiscal residence, expand permanent establishment to include prolonged cross border service provision, cap source taxation of dividends, interest, royalties and technical fees where the recipient is the beneficial owner, permit capital gains taxation for shares deriving mainly from immovable property, modify dependent personal services and student exemptions, restate elimination of double taxation by credit/deduction, strengthen exchange of information and assistance in tax collection, and add a Limitation of Benefits rule.
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Provisions expressly mentioned in the judgment/order text.
Tax Treaty Amendments expand permanent establishment rules, limit treaty benefits, cap source taxation and strengthen information exchange.
The Protocol amends the India-Poland tax treaty to revise taxes covered, territorial and fiscal definitions, broaden fiscal residence, expand permanent establishment to include prolonged cross border service provision, cap source taxation of dividends, interest, royalties and technical fees where the recipient is the beneficial owner, permit capital gains taxation for shares deriving mainly from immovable property, modify dependent personal services and student exemptions, restate elimination of double taxation by credit/deduction, strengthen exchange of information and assistance in tax collection, and add a Limitation of Benefits rule.
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