https://www.taxtmi.com/acts?id=43525 The Protocol provides that paragraph 4 of Article 8 will cease three years after entry into force; allows mutual agreement procedure for supervisory activities on approved turnkey projects meeting conditions (approval, turnkey nature, fee proportion cap, minimum project cost, duration limits, no tax avoidance), permitting taxation of supervisory fees in the project State at a rate not exceeding that applicable under Article 12 for royalties and technical service fees; and permits either State to tax permanent establishment profits at a higher rate than for similar domestic enterprises subject to a capped differential and non discrimination, with the Protocol integral to the Agreement and English operative on divergence. en-us Thu, 18 Jul 2024 11:17:49 +0530 Fri, 06 Dec 2024 13:27:15 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=43525 The Protocol provides that paragraph 4 of Article 8 will cease three years after entry into force; allows mutual agreement procedure for supervisory activities on approved turnkey projects meeting conditions (approval, turnkey nature, fee proportion cap, minimum project cost, duration limits, no tax avoidance), permitting taxation of supervisory fees in the project State at a rate not exceeding that applicable under Article 12 for royalties and technical service fees; and permits either State to tax permanent establishment profits at a higher rate than for similar domestic enterprises subject to a capped differential and non discrimination, with the Protocol integral to the Agreement and English operative on divergence. Act-Rules DTAA Thu, 18 Jul 2024 11:17:49 +0530 https://www.taxtmi.com/acts?id=43525