https://www.taxtmi.com/news?id=21907 The Japan-India Convention, as amended by Protocols and modified by the MLI, allocates taxing rights for income categories, defines residence and key terms, and sets PE rules and profit attribution. The MLI narrows specific activity exemptions, treats commissionnaire and similar arrangements as creating a PE where contracts are habitually concluded or driven, provides a dual resident entity tie breaker that can deny treaty relief if no competent authority agreement is reached, and includes anti abuse and transfer pricing corresponding adjustment mechanisms. The Convention establishes withholding rate ceilings for dividends, interest, royalties and technical fees, mutual agreement and information exchange procedures, and mutual assistance in tax collection. en-us Mon, 26 Aug 2019 18:24:29 +0530 Wed, 11 Feb 2026 15:58:28 +0530 TaxTMI RSS Generator https://www.taxtmi.com/news?id=21907 The Japan-India Convention, as amended by Protocols and modified by the MLI, allocates taxing rights for income categories, defines residence and key terms, and sets PE rules and profit attribution. The MLI narrows specific activity exemptions, treats commissionnaire and similar arrangements as creating a PE where contracts are habitually concluded or driven, provides a dual resident entity tie breaker that can deny treaty relief if no competent authority agreement is reached, and includes anti abuse and transfer pricing corresponding adjustment mechanisms. The Convention establishes withholding rate ceilings for dividends, interest, royalties and technical fees, mutual agreement and information exchange procedures, and mutual assistance in tax collection. News - Mon, 26 Aug 2019 18:24:29 +0530 https://www.taxtmi.com/news?id=21907