Permanent establishment: preparatory or auxiliary activities excluded and purchase-for-export profits not attributed; treaty updates tax and credit rules. Protocol updates the India-Japan tax treaty by adding the Companies (Profits) Surtax to covered taxes, excluding certain preparatory or auxiliary fixed places from being a permanent establishment, providing that no profit is attributed to establishments limited to purchase-for-export operations, increasing a specified rate of reduction in Article V, and prescribing deemed paid credit rules linked to Indian special incentive measures subject to intergovernmental agreement; it also sets ratification, entry into force, applicability periods and abrogates the prior Protocol.
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.
Permanent establishment: preparatory or auxiliary activities excluded and purchase-for-export profits not attributed; treaty updates tax and credit rules.
Protocol updates the India-Japan tax treaty by adding the Companies (Profits) Surtax to covered taxes, excluding certain preparatory or auxiliary fixed places from being a permanent establishment, providing that no profit is attributed to establishments limited to purchase-for-export operations, increasing a specified rate of reduction in Article V, and prescribing deemed paid credit rules linked to Indian special incentive measures subject to intergovernmental agreement; it also sets ratification, entry into force, applicability periods and abrogates the prior Protocol.
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