https://www.taxtmi.com/notifications?id=142574 Bilateral Convention allocates taxing rights between India and the United States, defines residence and permanent establishment, prescribes withholding ceilings for dividends, interest, royalties and fees for included services, and provides arm's-length profit attribution, limitation-on-benefits, non-discrimination, and MAP-based dispute resolution. Article 28 requires exchange of information with confidentiality safeguards. The Protocol and memoranda clarify scope of included services and PE agency rules, and an MoU with administrative Instructions permits suspension of tax collection during MAP on specified conditions, including provision of a bank guarantee. en-us Thu, 20 Dec 1990 00:00:00 +0530 Tue, 08 Oct 2024 14:34:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/notifications?id=142574 Bilateral Convention allocates taxing rights between India and the United States, defines residence and permanent establishment, prescribes withholding ceilings for dividends, interest, royalties and fees for included services, and provides arm's-length profit attribution, limitation-on-benefits, non-discrimination, and MAP-based dispute resolution. Article 28 requires exchange of information with confidentiality safeguards. The Protocol and memoranda clarify scope of included services and PE agency rules, and an MoU with administrative Instructions permits suspension of tax collection during MAP on specified conditions, including provision of a bank guarantee. Notifications Income Tax Thu, 20 Dec 1990 00:00:00 +0530 https://www.taxtmi.com/notifications?id=142574