https://www.taxtmi.com/caselaws?id=327447 Under the India-France DTAA, the permanent establishment fiction treats the Indian branch as distinct only for attributing business profits and does not make interest paid internally to the head office or overseas branches taxable as separate income of the foreign enterprise. The banking-specific treaty provision permits deduction of such intra-enterprise interest in computing branch profits, while the interest article does not independently tax it. The non-discrimination clause does not secure the domestic-company or co-operative-bank tax rate. Marketing-service remuneration does not accrue until consideration is finalised and capable of quantification; related delayed-payment interest cannot arise before the underlying liability crystallises. en-us Thu, 31 Mar 2016 00:00:00 +0530 Mon, 20 Jul 2026 15:40:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=327447 Under the India-France DTAA, the permanent establishment fiction treats the Indian branch as distinct only for attributing business profits and does not make interest paid internally to the head office or overseas branches taxable as separate income of the foreign enterprise. The banking-specific treaty provision permits deduction of such intra-enterprise interest in computing branch profits, while the interest article does not independently tax it. The non-discrimination clause does not secure the domestic-company or co-operative-bank tax rate. Marketing-service remuneration does not accrue until consideration is finalised and capable of quantification; related delayed-payment interest cannot arise before the underlying liability crystallises. Case-Laws Income Tax Thu, 31 Mar 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=327447