https://www.taxtmi.com/acts?id=4732 The treaty defines key concepts for tax allocation: territorial scope, "person" and "company" as taxable units, residency criteria based on incorporation or place of management and control, and "enterprise" as industrial or commercial undertakings. The permanent establishment rule treats a fixed place of business or specific projects as creating taxable presence, excludes mere storage and limited purchasing activity, and sets agency-based deeming conditions while excluding independent brokers and mere subsidiary relationships. Pension, annuity and competent authority are separately defined, and undefined treaty terms defer to domestic tax law. en-us Sat, 19 Jan 2008 22:45:54 +0530 Wed, 20 Nov 2024 15:36:55 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=4732 The treaty defines key concepts for tax allocation: territorial scope, "person" and "company" as taxable units, residency criteria based on incorporation or place of management and control, and "enterprise" as industrial or commercial undertakings. The permanent establishment rule treats a fixed place of business or specific projects as creating taxable presence, excludes mere storage and limited purchasing activity, and sets agency-based deeming conditions while excluding independent brokers and mere subsidiary relationships. Pension, annuity and competent authority are separately defined, and undefined treaty terms defer to domestic tax law. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=4732