https://www.taxtmi.com/acts?id=45598 Treaty clarifications allocate taxing powers: income is taxed when it arises; penalties and default charges are excluded from the term tax; a warehouse furnishing storage for others constitutes a permanent establishment; the resident State may tax income from property and capital gains; domestic law referenced must not be less favourable than at signature. The Protocol preserves States' measures on thin capitalisation, allows each State to set burden-of-proof rules for deductibility, limits rate differentials on taxing permanent-establishment profits, and confines "economic development" to industrial or infrastructural development. en-us Fri, 18 Oct 2024 18:01:46 +0530 Wed, 23 Oct 2024 16:29:08 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=45598 Treaty clarifications allocate taxing powers: income is taxed when it arises; penalties and default charges are excluded from the term tax; a warehouse furnishing storage for others constitutes a permanent establishment; the resident State may tax income from property and capital gains; domestic law referenced must not be less favourable than at signature. The Protocol preserves States' measures on thin capitalisation, allows each State to set burden-of-proof rules for deductibility, limits rate differentials on taxing permanent-establishment profits, and confines "economic development" to industrial or infrastructural development. Act-Rules DTAA Fri, 18 Oct 2024 18:01:46 +0530 https://www.taxtmi.com/acts?id=45598