https://www.taxtmi.com/caselaws?id=439947 Receipts from head office services linked to an Indian permanent establishment must be characterised under the treaty by examining whether they fall within the protocol's protected categories, rather than being taxed automatically as fee for technical services; the tax treatment depends on the nature of the income and its connection with the establishment. Head-office office and administrative claims are deductible only on reliable proof that they were actually incurred for the permanent establishment, subject to domestic-law limits; unsupported or markup-based claims are not allowable. Interest on an income-tax refund may fall within the business profits article where the underlying debt claim is effectively connected with the permanent establishment, displacing the concessional interest article. en-us Mon, 03 Apr 2023 00:00:00 +0530 Thu, 06 Jul 2023 08:05:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=439947 Receipts from head office services linked to an Indian permanent establishment must be characterised under the treaty by examining whether they fall within the protocol's protected categories, rather than being taxed automatically as fee for technical services; the tax treatment depends on the nature of the income and its connection with the establishment. Head-office office and administrative claims are deductible only on reliable proof that they were actually incurred for the permanent establishment, subject to domestic-law limits; unsupported or markup-based claims are not allowable. Interest on an income-tax refund may fall within the business profits article where the underlying debt claim is effectively connected with the permanent establishment, displacing the concessional interest article. Case-Laws Income Tax Mon, 03 Apr 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=439947