Words and Phrases - "effectively connected"

a
86
b
44
c
76
d
50
e
38
f
31
g
18
h
14
i
73
j
2
k
2
l
32
m
56
n
25
o
38
p
80
q
3
r
76
s
89
t
46
u
15
v
9
w
23
y
2

Tech Mahindra Limited v Commissioner of Taxation, [2016] FCAFC 130

Summary Under
Tax Topics - Treaties - Income Tax Conventions - Article 12
exception in the Australia-India Treaty for “effectively connected” royalties was not intended to exempt royalties not attributable to the source country PE from source country withholding

The Indian-resident taxpayer performed services for its Australian customers from its offices in India and through an Australian permanent...

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Words and Phrases
effectively connected