Double taxation avoidance: Protocol revises treaty rules, withholding limits, PE criteria, and exchange of information protections. Protocol amends the India-Poland tax treaty by specifying covered taxes and territorial definitions, expanding resident and permanent establishment rules (including service PE based on aggregate six month activity), modernizing associated enterprises/transfer pricing adjustments, setting withholding tax ceilings on dividends, interest and royalties/technical fees with defined exceptions, permitting taxation of gains from alienation of shares tied to immovable property, revising personal services and student/apprentice exemptions, strengthening exchange of information and mutual assistance in tax collection, and adding a Limitation of Benefits clause; effective in India from the fiscal year beginning after entry into force.
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Provisions expressly mentioned in the judgment/order text.
Double taxation avoidance: Protocol revises treaty rules, withholding limits, PE criteria, and exchange of information protections.
Protocol amends the India-Poland tax treaty by specifying covered taxes and territorial definitions, expanding resident and permanent establishment rules (including service PE based on aggregate six month activity), modernizing associated enterprises/transfer pricing adjustments, setting withholding tax ceilings on dividends, interest and royalties/technical fees with defined exceptions, permitting taxation of gains from alienation of shares tied to immovable property, revising personal services and student/apprentice exemptions, strengthening exchange of information and mutual assistance in tax collection, and adding a Limitation of Benefits clause; effective in India from the fiscal year beginning after entry into force.
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