Words and Phrases - "effectively connected"

a
82
b
44
c
75
d
50
e
37
f
31
g
17
h
13
i
71
j
2
k
2
l
30
m
51
n
25
o
38
p
79
q
2
r
73
s
85
t
44
u
14
v
8
w
20
y
2
“
1

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