https://www.taxtmi.com/news?id=1483 The revised agreement replaces the prior Convention and: permits determination of an entity's place of effective management via Mutual Agreement Procedure; creates an insurance permanent establishment; expands the Associated Enterprises provision to resolve transfer pricing disputes through Mutual Agreement Procedure; reduces source-state withholding rates on dividends and interest; removes limited tax sparing; adds an exchange of information article including banking information and broader information exchange; and introduces a Limitation of Benefit clause to prevent treaty misuse. en-us Wed, 02 Feb 2011 21:37:38 +0530 Wed, 02 Feb 2011 21:37:38 +0530 TaxTMI RSS Generator https://www.taxtmi.com/news?id=1483 The revised agreement replaces the prior Convention and: permits determination of an entity's place of effective management via Mutual Agreement Procedure; creates an insurance permanent establishment; expands the Associated Enterprises provision to resolve transfer pricing disputes through Mutual Agreement Procedure; reduces source-state withholding rates on dividends and interest; removes limited tax sparing; adds an exchange of information article including banking information and broader information exchange; and introduces a Limitation of Benefit clause to prevent treaty misuse. News - Wed, 02 Feb 2011 21:37:38 +0530 https://www.taxtmi.com/news?id=1483