Source taxation principle emphasized: concessional withholding on dividends, interest, royalties and technical fees to facilitate cross-border investment. A bilateral convention replacing the 1960 agreement emphasises the source taxation principle: business profits are taxable in the other state only if earned through a permanent establishment, and dividends, interest, royalties and fees for technical services are taxable in the source country at concessional rates; the Convention enters into force after exchange of instruments of ratification.
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.
Source taxation principle emphasized: concessional withholding on dividends, interest, royalties and technical fees to facilitate cross-border investment.
A bilateral convention replacing the 1960 agreement emphasises the source taxation principle: business profits are taxable in the other state only if earned through a permanent establishment, and dividends, interest, royalties and fees for technical services are taxable in the source country at concessional rates; the Convention enters into force after exchange of instruments of ratification.
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