https://www.taxtmi.com/news?id=1165 The Paper proposes that neither a DTAA nor the Direct Tax Code enjoys automatic precedence; the later-in-time provision prevails. It retains the prevailing rule that the option more beneficial to the taxpayer applies between domestic law and a relevant DTAA, but institutes a limited treaty override: DTAAs will not prevail where domestic anti avoidance measures apply, specifically under the General Anti Avoidance Rule, Controlled Foreign Corporation rules, or when a Branch Profits Tax is levied. en-us Tue, 15 Jun 2010 22:40:24 +0530 Tue, 15 Jun 2010 22:40:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/news?id=1165 The Paper proposes that neither a DTAA nor the Direct Tax Code enjoys automatic precedence; the later-in-time provision prevails. It retains the prevailing rule that the option more beneficial to the taxpayer applies between domestic law and a relevant DTAA, but institutes a limited treaty override: DTAAs will not prevail where domestic anti avoidance measures apply, specifically under the General Anti Avoidance Rule, Controlled Foreign Corporation rules, or when a Branch Profits Tax is levied. News - Tue, 15 Jun 2010 22:40:24 +0530 https://www.taxtmi.com/news?id=1165