Permanent establishment rules determine taxation of cross border business profits, with source concessions and credit relief. The treaty allocates taxing rights so business profits are taxable in the other state only if a permanent establishment exists; exempts international aircraft profits and provides specified source exemptions and limits for shipping profits; subjects dividends, interest, royalties and technical fees to concessional source rates; prescribes that India will relieve double taxation by the credit method while the other state will eliminate double taxation under its law taking into account taxes paid or spared in India; entry into force follows completion of domestic formalities.
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 rules determine taxation of cross border business profits, with source concessions and credit relief.
The treaty allocates taxing rights so business profits are taxable in the other state only if a permanent establishment exists; exempts international aircraft profits and provides specified source exemptions and limits for shipping profits; subjects dividends, interest, royalties and technical fees to concessional source rates; prescribes that India will relieve double taxation by the credit method while the other state will eliminate double taxation under its law taking into account taxes paid or spared in India; entry into force follows completion of domestic formalities.
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