Article 5(5) - India USA Treaty - Independent Agent - International Taxation - +91-9667714335

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Article 5(5) - India USA Treaty - Independent Agent - CA Final International Taxation - CA Arinjay Jain

ARTICLE 5(5) – INDIA USA TREATY – INDEPENDENT AGENT
An enterprise of a Contracting State shall not be deemed to have a permanent establishment in the other Contracting State merely because it carries on business in that other State through a broker, general commission agent, or any other agent of an independent status. provided that such persons are acting in the ordinary course of their business.
However, when the activities of such an agent are devoted wholly or almost wholly on behalf of that enterprise and the transactions between the agent and the enterprise are not made under arm's length conditions, he shall not be considered an agent of independent status within the meaning of this paragraph

INDEPENDENT AGENT
Broker, general commission agent, or any other agent of an independent status
Acting in the ordinary course of their business
Activities are devoted wholly or almost wholly on behalf
Transactions between the agent and the enterprise are not made at ALP