https://www.taxtmi.com/article/detailed?id=14929 The document explains that Indian taxation depends on the nexus of residence and source: corporate residency via Place of Effective Management subjects companies to tax on global profits, while business connection, Significant Economic Presence and Permanent Establishment rules determine source-based taxation. Dependent agents who habitually conclude or play a principal role in contracts can create taxable connections or PE; independent agents generally do not. The MLI broadens dependent-agent PE and includes anti-fragmentation rules. The "make available" test governs whether software or services amount to royalty or FTS; mere use without transfer of know-how does not meet that test. en-us Wed, 06 Aug 2025 08:20:27 +0530 Wed, 06 Aug 2025 08:20:27 +0530 TaxTMI RSS Generator https://www.taxtmi.com/article/detailed?id=14929 The document explains that Indian taxation depends on the nexus of residence and source: corporate residency via Place of Effective Management subjects companies to tax on global profits, while business connection, Significant Economic Presence and Permanent Establishment rules determine source-based taxation. Dependent agents who habitually conclude or play a principal role in contracts can create taxable connections or PE; independent agents generally do not. The MLI broadens dependent-agent PE and includes anti-fragmentation rules. The "make available" test governs whether software or services amount to royalty or FTS; mere use without transfer of know-how does not meet that test. Articles Income Tax Wed, 06 Aug 2025 08:20:27 +0530 https://www.taxtmi.com/article/detailed?id=14929