https://www.taxtmi.com/acts?id=44871 The Protocol permits taxation in both Contracting States of income from immovable property and related capital gains and of directors' fees. For building sites and similar projects, only profits from the permanent establishment's own activities are attributed to it; deliveries of machinery or equipment from outside that State are excluded, and administrative expenses incurred outside India are deductible under section 44C of the Indian Income tax Act, 1961. The Protocol also fixes source taxation ceilings on distributed profits and applies a most favoured nation rule for dividends, interest, royalties and technical fees. en-us Wed, 16 Oct 2024 15:57:42 +0530 Tue, 22 Oct 2024 15:16:14 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=44871 The Protocol permits taxation in both Contracting States of income from immovable property and related capital gains and of directors' fees. For building sites and similar projects, only profits from the permanent establishment's own activities are attributed to it; deliveries of machinery or equipment from outside that State are excluded, and administrative expenses incurred outside India are deductible under section 44C of the Indian Income tax Act, 1961. The Protocol also fixes source taxation ceilings on distributed profits and applies a most favoured nation rule for dividends, interest, royalties and technical fees. Act-Rules DTAA Wed, 16 Oct 2024 15:57:42 +0530 https://www.taxtmi.com/acts?id=44871