https://www.taxtmi.com/notifications?id=22326 The Protocol revises treaty rules on allocation and source taxation by: allowing permanent establishments deductions for business expenses subject to host-State limitations and a fallback deduction cap where domestic law disallows such deductions; disallowing certain payments from a permanent establishment to head office (royalties, commissions, management fees and, except for banks, interest) except reimbursements; imposing reduced source-state taxation on shipping income, dividends, interest, and royalties/technical fees with specified caps and definitions; and taxing independent personal services in the source State when presence exceeds the 183-day threshold or a fixed base exists, while adjusting foreign tax credit computation and specifying entry into force and application rules. en-us Wed, 02 Mar 1988 00:00:00 +0530 Fri, 27 Dec 2024 16:53:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/notifications?id=22326 The Protocol revises treaty rules on allocation and source taxation by: allowing permanent establishments deductions for business expenses subject to host-State limitations and a fallback deduction cap where domestic law disallows such deductions; disallowing certain payments from a permanent establishment to head office (royalties, commissions, management fees and, except for banks, interest) except reimbursements; imposing reduced source-state taxation on shipping income, dividends, interest, and royalties/technical fees with specified caps and definitions; and taxing independent personal services in the source State when presence exceeds the 183-day threshold or a fixed base exists, while adjusting foreign tax credit computation and specifying entry into force and application rules. Notifications Income Tax Wed, 02 Mar 1988 00:00:00 +0530 https://www.taxtmi.com/notifications?id=22326