https://www.taxtmi.com/acts?id=45670 The clarifies that an Irish resident's share of partnership profits from a partnership resident in India remains taxable in Ireland but is treated as income from Indian sources for Article 23 credit purposes; permits a Contracting State to apportion total enterprise profits to determine taxable profits of an insurance permanent establishment provided the method conforms to Article 7 principles; allows India to tax a permanent establishment of an Irish company at a higher rate than similar domestic companies without contravening Article 24; and records Ireland's commitment to negotiate collection-assistance provisions if its domestic law changes, alongside agreed temporal amendments substituting calendar-year references for certain fiscal-year dates. en-us Mon, 18 Nov 2024 14:26:22 +0530 Fri, 06 Dec 2024 11:39:20 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=45670 The clarifies that an Irish resident's share of partnership profits from a partnership resident in India remains taxable in Ireland but is treated as income from Indian sources for Article 23 credit purposes; permits a Contracting State to apportion total enterprise profits to determine taxable profits of an insurance permanent establishment provided the method conforms to Article 7 principles; allows India to tax a permanent establishment of an Irish company at a higher rate than similar domestic companies without contravening Article 24; and records Ireland's commitment to negotiate collection-assistance provisions if its domestic law changes, alongside agreed temporal amendments substituting calendar-year references for certain fiscal-year dates. Act-Rules DTAA Mon, 18 Nov 2024 14:26:22 +0530 https://www.taxtmi.com/acts?id=45670