https://www.taxtmi.com/acts?id=45661 The requires that profits attributable to a permanent establishment be determined solely by the remuneration attributable to the establishment's actual activities, with contract profits apportioned between establishment and head office according to work performed locally; it prevents attribution based on mere facilitation of foreign trade, sets minimum allowable deductions for administrative expenses per Indian law at signature, excludes penalty amounts from being treated as interest, establishes a three year refund window for excess source taxation, and provides for application of lower withholding tax limitations and exemptions for dividends, interest, royalties and fees where later India-OECD Conventions or mutual agreements so limit source taxation. en-us Wed, 23 Oct 2024 12:43:59 +0530 Wed, 23 Oct 2024 12:43:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=45661 The requires that profits attributable to a permanent establishment be determined solely by the remuneration attributable to the establishment's actual activities, with contract profits apportioned between establishment and head office according to work performed locally; it prevents attribution based on mere facilitation of foreign trade, sets minimum allowable deductions for administrative expenses per Indian law at signature, excludes penalty amounts from being treated as interest, establishes a three year refund window for excess source taxation, and provides for application of lower withholding tax limitations and exemptions for dividends, interest, royalties and fees where later India-OECD Conventions or mutual agreements so limit source taxation. Act-Rules DTAA Wed, 23 Oct 2024 12:43:59 +0530 https://www.taxtmi.com/acts?id=45661