https://www.taxtmi.com/notifications?id=6315 The Protocol revises the Agreement by redefining resident status-India by liability to tax and exclusion of persons taxable only on source income; UAE by physical presence and corporate incorporation with management and control-and recognises specified government institutions. It permits deductions for permanent establishment expenses under the taxing State's laws, allows source State taxation of dividends subject to a cap for the beneficial owner, reallocates capital gains taxing rights for shares deriving value from immovable property, exempts government income from tax in the other State, revises nondiscrimination for permanent establishments, and adds a Limitation of Benefits clause denying benefits to entities formed to obtain treaty advantages. en-us Wed, 28 Nov 2007 00:00:00 +0530 Tue, 03 Dec 2024 16:54:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/notifications?id=6315 The Protocol revises the Agreement by redefining resident status-India by liability to tax and exclusion of persons taxable only on source income; UAE by physical presence and corporate incorporation with management and control-and recognises specified government institutions. It permits deductions for permanent establishment expenses under the taxing State's laws, allows source State taxation of dividends subject to a cap for the beneficial owner, reallocates capital gains taxing rights for shares deriving value from immovable property, exempts government income from tax in the other State, revises nondiscrimination for permanent establishments, and adds a Limitation of Benefits clause denying benefits to entities formed to obtain treaty advantages. Notifications Income Tax Wed, 28 Nov 2007 00:00:00 +0530 https://www.taxtmi.com/notifications?id=6315