https://www.taxtmi.com/acts?id=16645 The Protocol treats recognised pension funds as treaty residents, refines permanent establishment rules including taxation of service remuneration and contractual profits attributable to the PE, and limits PE creation by mere stock or delivery facilities. It denies Articles 10-12 and 22 benefits for conduit arrangements designed to route income to non residents, provides for application of lower source tax rates granted by later OECD member State treaties, clarifies taxation of gains from alienation under Articles 7, 12 and 13, permits limited differential PE tax rates, and sets procedural safeguards and scope for exchange of information and mutual agreement implementation. en-us Wed, 06 Jun 2012 13:31:15 +0530 Thu, 19 Dec 2024 15:51:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=16645 The Protocol treats recognised pension funds as treaty residents, refines permanent establishment rules including taxation of service remuneration and contractual profits attributable to the PE, and limits PE creation by mere stock or delivery facilities. It denies Articles 10-12 and 22 benefits for conduit arrangements designed to route income to non residents, provides for application of lower source tax rates granted by later OECD member State treaties, clarifies taxation of gains from alienation under Articles 7, 12 and 13, permits limited differential PE tax rates, and sets procedural safeguards and scope for exchange of information and mutual agreement implementation. Act-Rules DTAA Wed, 06 Jun 2012 13:31:15 +0530 https://www.taxtmi.com/acts?id=16645