https://www.taxtmi.com/acts?id=37663 The Protocol fixes that profits of a permanent establishment are to be determined only on receipts attributable to the permanent establishment's actual activities in the State where it is located, including the portion of contract income effectively performed by that establishment. It provides that domestic-law provisions that are more beneficial to a resident of the other Contracting State shall prevail over the treaty. It also records an agreed dividend withholding rate under Article 10 subject to review after three years, with the agreed rate continuing if not reviewed. en-us Thu, 19 Sep 2019 12:37:41 +0530 Wed, 27 Nov 2024 12:18:43 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=37663 The Protocol fixes that profits of a permanent establishment are to be determined only on receipts attributable to the permanent establishment's actual activities in the State where it is located, including the portion of contract income effectively performed by that establishment. It provides that domestic-law provisions that are more beneficial to a resident of the other Contracting State shall prevail over the treaty. It also records an agreed dividend withholding rate under Article 10 subject to review after three years, with the agreed rate continuing if not reviewed. Act-Rules DTAA Thu, 19 Sep 2019 12:37:41 +0530 https://www.taxtmi.com/acts?id=37663