https://www.taxtmi.com/acts?id=43445 The Protocol clarifies PE timing and short term activity aggregation, mandates a minimum deduction for executive and administrative expenses no less than Indian law, confirms that income attributable to a PE or fixed base is taxable where situated even if payments are deferred, limits Article 14 coverage to profits taxed in the United States on a net income basis, explains US taxation and a cap on taxes for fees for included services, elaborates the Article 12 tests distinguishing ancillary/subsidiary services and services that make technology available, lists exclusions under paragraph 5, records absence of a tax sparing credit at signature, and sets a four part habitual agent test. en-us Mon, 08 Jul 2024 13:27:43 +0530 Thu, 26 Dec 2024 15:40:37 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=43445 The Protocol clarifies PE timing and short term activity aggregation, mandates a minimum deduction for executive and administrative expenses no less than Indian law, confirms that income attributable to a PE or fixed base is taxable where situated even if payments are deferred, limits Article 14 coverage to profits taxed in the United States on a net income basis, explains US taxation and a cap on taxes for fees for included services, elaborates the Article 12 tests distinguishing ancillary/subsidiary services and services that make technology available, lists exclusions under paragraph 5, records absence of a tax sparing credit at signature, and sets a four part habitual agent test. Act-Rules DTAA Mon, 08 Jul 2024 13:27:43 +0530 https://www.taxtmi.com/acts?id=43445