https://www.taxtmi.com/circulars?id=10549 Taxation of a permanent establishment under the Non-Discrimination article of DTAAs must not be less favourable than taxation of domestic enterprises. Indian law treats a company that makes prescribed arrangements for dividend declaration and payment in India as a domestic company for tax-rate purposes; therefore Finance Act distinctions for "foreign company" do not, per se, amount to discrimination against a PE. Some DTAAs expressly permit higher rates for PEs, making explicit what is implicit where that sentence is absent. en-us Tue, 11 Apr 2000 00:00:00 +0530 Wed, 15 Jun 2011 13:06:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/circulars?id=10549 Taxation of a permanent establishment under the Non-Discrimination article of DTAAs must not be less favourable than taxation of domestic enterprises. Indian law treats a company that makes prescribed arrangements for dividend declaration and payment in India as a domestic company for tax-rate purposes; therefore Finance Act distinctions for "foreign company" do not, per se, amount to discrimination against a PE. Some DTAAs expressly permit higher rates for PEs, making explicit what is implicit where that sentence is absent. Circulars Income Tax Tue, 11 Apr 2000 00:00:00 +0530 https://www.taxtmi.com/circulars?id=10549