https://www.taxtmi.com/acts?id=37371 An anti-abuse provision denies Covered Tax Agreement benefits when a resident treats income as attributable to a permanent establishment in a third jurisdiction and profits are exempt in the residence jurisdiction, if tax in the third jurisdiction is less than sixty percent of the tax that would have applied had the permanent establishment been situated in the residence jurisdiction; such income remains taxable under the source jurisdiction's domestic law. The rule includes an active business exception and permits competent authority relief upon request and consultation. en-us Tue, 20 Aug 2019 16:25:02 +0530 Mon, 10 Feb 2025 16:29:17 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=37371 An anti-abuse provision denies Covered Tax Agreement benefits when a resident treats income as attributable to a permanent establishment in a third jurisdiction and profits are exempt in the residence jurisdiction, if tax in the third jurisdiction is less than sixty percent of the tax that would have applied had the permanent establishment been situated in the residence jurisdiction; such income remains taxable under the source jurisdiction's domestic law. The rule includes an active business exception and permits competent authority relief upon request and consultation. Act-Rules DTAA Tue, 20 Aug 2019 16:25:02 +0530 https://www.taxtmi.com/acts?id=37371