https://www.taxtmi.com/notifications?id=22229 The Convention allocates taxing rights between contracting States for taxes on income and capital, applies to residents, and defines residence tie breakers and key terms. A permanent establishment test (fixed place and agent rules, construction site thresholds) determines business taxing nexus; profits attributable to a permanent establishment are computed as if it were a separate enterprise with prescribed deduction limits. Dividends, interest, royalties and service fees are subject to specified taxing rights and maximum source withholding rates, and double taxation is eliminated by detailed credit or exemption methods. The treaty provides mutual agreement, information exchange, entry into force and termination rules. en-us Tue, 20 Nov 1984 00:00:00 +0530 Thu, 05 Dec 2024 16:42:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/notifications?id=22229 The Convention allocates taxing rights between contracting States for taxes on income and capital, applies to residents, and defines residence tie breakers and key terms. A permanent establishment test (fixed place and agent rules, construction site thresholds) determines business taxing nexus; profits attributable to a permanent establishment are computed as if it were a separate enterprise with prescribed deduction limits. Dividends, interest, royalties and service fees are subject to specified taxing rights and maximum source withholding rates, and double taxation is eliminated by detailed credit or exemption methods. The treaty provides mutual agreement, information exchange, entry into force and termination rules. Notifications Income Tax Tue, 20 Nov 1984 00:00:00 +0530 https://www.taxtmi.com/notifications?id=22229