https://www.taxtmi.com/notifications?id=22249 The Protocol revises residence and tie breaker rules, modernises the definition of permanent establishment including specified inclusions and exclusions and a six month rule for construction sites, and confines source taxation to profits attributable to a PE determined on an arm's length basis with allowed deductions for PE expenses. It also sets capped withholding rates and detailed rules for dividends, interest, royalties and technical fees, allocates capital taxation by situs or residence, and prescribes methods for elimination of double taxation and a mutual agreement procedure for resolving treaty application disputes. en-us Mon, 26 Aug 1985 00:00:00 +0530 Wed, 01 Jan 2025 15:31:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/notifications?id=22249 The Protocol revises residence and tie breaker rules, modernises the definition of permanent establishment including specified inclusions and exclusions and a six month rule for construction sites, and confines source taxation to profits attributable to a PE determined on an arm's length basis with allowed deductions for PE expenses. It also sets capped withholding rates and detailed rules for dividends, interest, royalties and technical fees, allocates capital taxation by situs or residence, and prescribes methods for elimination of double taxation and a mutual agreement procedure for resolving treaty application disputes. Notifications Income Tax Mon, 26 Aug 1985 00:00:00 +0530 https://www.taxtmi.com/notifications?id=22249