TaxTMI Login
Just a moment...
By creating an account you can:
Press 'Enter' to add multiple search terms. Rules for Better Search
of 
of 
No Folders have been created
Are you sure you want to delete "My most important" ?
NOTE:
of of 
All TMI Notes
of of All TMI Notes
Note
Bookmark
Share
Don't have an account? Register Here
of <h1>Clause 207 fixes non-resident tax rates, limits deductions, bars Chapter VIII relief; Act preserves s59 and denies Schedule XV deductions</h1> Clause 207 imposes fixed, head-specific tax rates on non-residents and foreign companies for dividends, specified interest, distributed/unit income, royalties and fees for technical services, limiting deductions and barring Chapter VIII relief where such incomes constitute the sole gross total income. The enacted Act mainly cleans wording but substantively differs from the Bill by (1) excluding section 59 from the disallowance range (preserving certain statutory exclusions) while the Bill's '28-61' would include it, and (2) expressly denying Schedule XV deductions in the Act whereas the Bill does not; these drafting differences affect allowable expense offsets and potential treaty/interpretation disputes.
TaxTMI 
TaxTMI 