https://www.taxtmi.com/acts?id=43542 The treaty permits source-state taxation of immovable property, capital gains from immovable property, directors' fees, and profits of construction or installation permanent establishments limited to profits attributable to the establishment; deliveries of machinery or equipment from outside the State are excluded from attribution. Administrative expenses incurred outside India are deductible under the corresponding Indian income tax provision. Dividend taxation by India is subject to a capped source withholding rate, and a most-favoured-nation rule makes lower rates or narrower scopes in OECD-member conventions applicable here for dividends, interest, royalties and fees for technical services. Source-State may impose a limited differential tax on permanent establishment profits and a capped additional tax on profits of an Indian resident company with a permanent establishment in Hungary. en-us Mon, 22 Jul 2024 17:29:47 +0530 Wed, 04 Dec 2024 12:03:29 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=43542 The treaty permits source-state taxation of immovable property, capital gains from immovable property, directors' fees, and profits of construction or installation permanent establishments limited to profits attributable to the establishment; deliveries of machinery or equipment from outside the State are excluded from attribution. Administrative expenses incurred outside India are deductible under the corresponding Indian income tax provision. Dividend taxation by India is subject to a capped source withholding rate, and a most-favoured-nation rule makes lower rates or narrower scopes in OECD-member conventions applicable here for dividends, interest, royalties and fees for technical services. Source-State may impose a limited differential tax on permanent establishment profits and a capped additional tax on profits of an Indian resident company with a permanent establishment in Hungary. Act-Rules DTAA Mon, 22 Jul 2024 17:29:47 +0530 https://www.taxtmi.com/acts?id=43542