Double taxation agreement limits taxation of business profits to the country where a permanent establishment exists, with concessional source taxation. The Convention provides that business profits of an enterprise of one Contracting State are taxable in the other State only if the enterprise operates through a permanent establishment there; it also makes mutual exemption for shipping and aircraft profits and prescribes concessional source-country taxation for dividends, interest, royalties and specified service fees, with entry into force upon exchange of notes confirming completion of each State's legal procedures.
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.
Double taxation agreement limits taxation of business profits to the country where a permanent establishment exists, with concessional source taxation.
The Convention provides that business profits of an enterprise of one Contracting State are taxable in the other State only if the enterprise operates through a permanent establishment there; it also makes mutual exemption for shipping and aircraft profits and prescribes concessional source-country taxation for dividends, interest, royalties and specified service fees, with entry into force upon exchange of notes confirming completion of each State's legal procedures.
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