https://www.taxtmi.com/acts?id=44685 The Protocol clarifies that Indian-company dividends are presently exempt under domestic law and thus not subject to treaty withholding while that exemption continues; capital gains on shares acquired before a specified cutoff date are taxable only in the alienator's State of residence; paragraph 3 of Article 24 does not bar a State from taxing profits of a non-resident company's permanent establishment at a higher rate than for similar domestic companies; and Article 27 does not oblige a State to act contrary to its laws, administrative practices, or public policy in tax collection. en-us Wed, 16 Oct 2024 12:48:46 +0530 Tue, 22 Oct 2024 11:36:40 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=44685 The Protocol clarifies that Indian-company dividends are presently exempt under domestic law and thus not subject to treaty withholding while that exemption continues; capital gains on shares acquired before a specified cutoff date are taxable only in the alienator's State of residence; paragraph 3 of Article 24 does not bar a State from taxing profits of a non-resident company's permanent establishment at a higher rate than for similar domestic companies; and Article 27 does not oblige a State to act contrary to its laws, administrative practices, or public policy in tax collection. Act-Rules DTAA Wed, 16 Oct 2024 12:48:46 +0530 https://www.taxtmi.com/acts?id=44685