Article 22 of India-Switzerland DTAA: Non-resident shipping companies' tax obligations clarified for ships not linked to agency PE.

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....Benefit of Article 22 of DTAA between India and Switzerland - Where the ships are owned or chartered by a non-resident shipping company and the agency PE merely clears inbound cargo and books outbound cargo and carries out similar ancillary functions, the ships are clearly not the assets of the PE nor are they is some other way effectively connected with a permanent establishment. - AT....