January 19, 2010
Show AI Summary
Withholding tax reductions boost cross-border investment under revised DTAA with expanded information exchange and limitation of benefits clause enhances treaty integrity.
The revised bilateral tax agreement reduces withholding taxes on distributions and payments to encourage investment and technology transfer, harmonizes withholding treatment for royalties and technical service fees, and strengthens information exchange by preventing refusal of requests solely for lack of domestic interest or because information is held by banks. It adds a Limitation of Benefits clause to prevent treaty misuse, expands permanent establishment rules to include service PE, extends the time test for independent personal services, broadens the Mutual Agreement Procedure for relief from double taxation, and introduces assistance in collection of taxes, subject to each State's internal completion procedures.