https://www.taxtmi.com/acts?id=45220 The Protocol provides that paragraph 4 of Article 8 lapses three years after entry into force; permits mutual agreement procedure for supervisory activities on qualifying turnkey projects meeting specified conditions (government approval, fee and cost thresholds, duration limits, and absence of tax avoidance), allowing taxation in the project State of supervisory fees at up to the Article 12 rate for royalties and technical service fees; and authorises either Contracting State to tax a permanent establishment at a higher rate than domestic counterparts subject to a capped differential and a requirement of no less favourable treatment than third-country permanent establishments. en-us Thu, 17 Oct 2024 17:41:26 +0530 Tue, 22 Oct 2024 16:49:08 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=45220 The Protocol provides that paragraph 4 of Article 8 lapses three years after entry into force; permits mutual agreement procedure for supervisory activities on qualifying turnkey projects meeting specified conditions (government approval, fee and cost thresholds, duration limits, and absence of tax avoidance), allowing taxation in the project State of supervisory fees at up to the Article 12 rate for royalties and technical service fees; and authorises either Contracting State to tax a permanent establishment at a higher rate than domestic counterparts subject to a capped differential and a requirement of no less favourable treatment than third-country permanent establishments. Act-Rules DTAA Thu, 17 Oct 2024 17:41:26 +0530 https://www.taxtmi.com/acts?id=45220