Arm's-length dependent-agent remuneration can preclude further profit attribution, while refund interest may fall under treaty interest provisions.

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....Arm's-length remuneration of an Indian associated enterprise treated as a dependent agent permanent establishment is discussed as precluding further profit attribution to the non-resident where no transfer-pricing adjustment is made. The notes describe this approach as applying on identical facts to challenges concerning business connection, permanent establishment and attribution of profits. They also address interest on an income-tax refund, stating that it is not effectively connected with the alleged Indian permanent establishment and should be taxed under the interest article of the India-Singapore treaty rather than under normal domestic provisions.....