https://www.taxtmi.com/acts?id=18025 The Protocol clarifies that the time limit for Article 5(3)(a) begins when a construction, installation or assembly project or supervisory activity itself begins, excluding preparatory activities and time taken to obtain licences; confirms that Article 24's nondiscrimination clause does not preclude India from applying a higher tax rate to profits attributable to a permanent establishment of an Ethiopian company than to a similar domestic company nor conflict with Article 7(3); and provides that a Contracting State's domestic law more beneficial to a resident of the other State shall apply to the extent it is more favourable. en-us Mon, 22 Jul 2013 16:51:32 +0530 Sat, 30 Nov 2024 12:41:41 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=18025 The Protocol clarifies that the time limit for Article 5(3)(a) begins when a construction, installation or assembly project or supervisory activity itself begins, excluding preparatory activities and time taken to obtain licences; confirms that Article 24's nondiscrimination clause does not preclude India from applying a higher tax rate to profits attributable to a permanent establishment of an Ethiopian company than to a similar domestic company nor conflict with Article 7(3); and provides that a Contracting State's domestic law more beneficial to a resident of the other State shall apply to the extent it is more favourable. Act-Rules DTAA Mon, 22 Jul 2013 16:51:32 +0530 https://www.taxtmi.com/acts?id=18025