https://www.taxtmi.com/notifications?id=6316 The Agreement allocates taxing rights by category of income, designating permanent establishment as the principal nexus for business profits and providing arm's length attribution rules; immovable property income is taxable where located; shipping and air transport profits are taxable only in the enterprise's residence State. Dividends, interest and royalties may be taxed in the source State but withholding is limited where the recipient is the beneficial owner and special rules exclude amounts effectively connected with a PE or fixed base. The treaty also prescribes elimination of double taxation by credit, non discrimination, mutual agreement and exchange of information, and an anti abuse limitation of benefits clause. en-us Tue, 27 Nov 2007 00:00:00 +0530 Mon, 09 Dec 2024 12:32:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/notifications?id=6316 The Agreement allocates taxing rights by category of income, designating permanent establishment as the principal nexus for business profits and providing arm's length attribution rules; immovable property income is taxable where located; shipping and air transport profits are taxable only in the enterprise's residence State. Dividends, interest and royalties may be taxed in the source State but withholding is limited where the recipient is the beneficial owner and special rules exclude amounts effectively connected with a PE or fixed base. The treaty also prescribes elimination of double taxation by credit, non discrimination, mutual agreement and exchange of information, and an anti abuse limitation of benefits clause. Notifications Income Tax Tue, 27 Nov 2007 00:00:00 +0530 https://www.taxtmi.com/notifications?id=6316