https://www.taxtmi.com/notifications?id=142388 Treaty allocates taxing rights between residence and source: residence rules and a PE nexus determine taxation of business profits; immovable property, transport, dividends, interest, royalties, fees for technical services, capital gains and personal services have specific source allocations. Source taxation of dividends, interest and royalties is limited by prescribed withholding constraints when the recipient is beneficial owner; exemptions apply for certain public bodies and approved transactions. Double taxation is relieved by a credit method; the treaty provides non discrimination, a mutual agreement procedure with confidentiality safeguards, and exchange of information provisions. en-us Mon, 16 Sep 1996 00:00:00 +0530 Fri, 23 Aug 2024 16:42:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/notifications?id=142388 Treaty allocates taxing rights between residence and source: residence rules and a PE nexus determine taxation of business profits; immovable property, transport, dividends, interest, royalties, fees for technical services, capital gains and personal services have specific source allocations. Source taxation of dividends, interest and royalties is limited by prescribed withholding constraints when the recipient is beneficial owner; exemptions apply for certain public bodies and approved transactions. Double taxation is relieved by a credit method; the treaty provides non discrimination, a mutual agreement procedure with confidentiality safeguards, and exchange of information provisions. Notifications Income Tax Mon, 16 Sep 1996 00:00:00 +0530 https://www.taxtmi.com/notifications?id=142388