[ compiled answers ]
Rule-level answers, one page each.
Every page below is a compiled answer — a threshold, a test, a rate, a section mapping — with its pinpoint and, where the repo holds the primary text, a string-verified quote. Each has a JSON twin at the same path plus .json. These are the same objects the lookup_compiled_rule tool serves.
What is the construction PE day threshold under the India–Singapore treaty?India–SingaporesettledWhat is the construction PE day threshold under the India–USA treaty?India–USAsettledWhat is the Income-tax Act 2025 successor of Chapter X-A (GAAR, ss.95–102)?section mapsettledWhat is the Income-tax Act 2025 successor of Explanation to s.9(2) (Finance Act 2010)?section mapsettledWhat is the Income-tax Act 2025 successor of s.115A?section mapsettledWhat is the Income-tax Act 2025 successor of s.195?section mapsettledWhat is the Income-tax Act 2025 successor of s.195A?section mapsettledWhat is the Income-tax Act 2025 successor of s.197?section mapsettledWhat is the Income-tax Act 2025 successor of s.206AA?section mapsettledWhat is the Income-tax Act 2025 successor of s.2(37A)(iii)?section mapsettledWhat is the Income-tax Act 2025 successor of s.90?section mapsettledWhat is the Income-tax Act 2025 successor of s.92F(iiia)?section mapsettledWhat is the Income-tax Act 2025 successor of s.9(1)(i) Explanation 2A (SEP)?section mapsettledWhat is the Income-tax Act 2025 successor of s.9(1)(i) Explanations 4A–7 (indirect transfer)?section mapsettledWhat is the Income-tax Act 2025 successor of s.9(1)(vi) Explanation 2?section mapsettledWhat is the Income-tax Act 2025 successor of s.9(1)(vi) Explanation 4?section mapsettledWhat is the Income-tax Act 2025 successor of s.9(1)(vi) Explanations 5 and 6?section mapsettledWhat is the Income-tax Act 2025 successor of s.9(1)(vii) Explanation 2?section mapsettledWhat is the service PE day threshold under the India–Germany treaty?India–GermanysettledWhat is the service PE day threshold under the India–Netherlands treaty?India–NetherlandssettledWhat is the service PE day threshold under the India–Singapore treaty?India–SingaporesettledWhat is the service PE day threshold under the India–UAE treaty?India–UAEsettledWhat is the service PE day threshold under the India–UK treaty?India–UKsettledWhat is the service PE day threshold under the India–USA treaty?India–USAsettledWhat is the service PE day threshold under the USA–Canada treaty?USA–CanadasettledWhat is the Canadian Regulation 105 withholding rate on service fees?IndiaadministrativeDoes soliciting orders in Canada through an agent create a Canadian tax presence?IndiasettledDo seconded employees create a service PE?IndiajudicialDoes Circular 23/1969's arm's-length extinguishment still apply?IndiaadministrativeAre connected construction sites aggregated for the India–US day threshold?India–USAsettledWhat is the construction PE threshold under the India–US treaty?India–USAsettledWhat is the domestic securing-orders threshold under s.9(1)(i)?IndiasettledWhat is the domestic Indian tax rate on royalty and FTS paid to a non-resident?IndiasettledDoes Indian domestic law have a principal-role agency test?IndiasettledDoes the domestic stock-of-goods route require sales-contributing activities?IndiasettledWhat did e-Funds hold about outsourcing to an Indian subsidiary?IndiajudicialAre the four Exchange of Notes conditions conjunctive or alternatives?India–USAagreed_interpretationHow much income does a business connection actually tax in India?IndiasettledWhat did Formula One hold about disposal of a place?IndiajudicialFrom when does Indian GAAR apply?IndiasettledAre pre-2017 investments grandfathered from Indian GAAR?IndiajudicialWhat is the monetary floor below which Indian GAAR cannot apply?IndiaadministrativeDoes GAAR override a treaty election under s.90(2)?IndiasettledDoes exclusivity alone destroy an agent's independent status under the India–US treaty?India–USAsettledDoes the India–Netherlands treaty have a securing-orders limb?India–NetherlandssettledWhat agency authority does the India–UK treaty's dependent-agent limb require?India–UKsettledWhen does the 10% India–US royalty rate apply?India–USAsettledWhat is the India–US treaty withholding rate on royalties and fees for included services?India–USAsettledIs an Indian liaison office a PE?India–USAsettledWhat does 'make available' mean in the India–US FIS article?India–USAsettledCan a Netherlands, France or Switzerland payee claim a lower royalty/FTS rate through the MFN clause?IndiasettledWhich India treaty pairs does MLI Article 12 actually modify?IndiasettledWhat does the MLI Article 12 principal-role test require?IndiasettledAre MLI modifications enforceable in India after Sky High Leasing?IndiajudicialDoes arm's-length remuneration extinguish PE profit attribution?IndiajudicialMust a non-resident payer with no Indian presence deduct Indian tax at source?IndiasettledWhat withholding rate applies when the non-resident payee has no PAN?IndiasettledHow does a DTAA rate legally apply to withholding under section 393(2)?IndiasettledWhat happens to withholding when the Indian payer bears the tax under a net-of-tax contract?IndiasettledTreaty or the Income-tax Act — which applies to a non-resident?IndiasettledAre cost-to-cost secondment reimbursements to a foreign group entity taxable as FTS/FIS?IndiacontestedWhen does habitually securing orders create a PE under the India–US treaty?India–USAagreed_interpretationWhat are the significant economic presence thresholds in India?IndiasettledWhat is the India–Singapore service PE threshold, and does it change for related enterprises?India–SingaporesettledWhat is the service PE day threshold under the India–UK treaty?India–UKsettledWhat is the service PE day threshold under the India–US treaty?India–USAsettledIs there a day threshold for services to a related enterprise under the India–US treaty?India–USAsettledAre payments to a non-resident for software licences royalty under Indian law?IndiasettledWhat does the India–US stock limb require beyond maintaining stock and delivering?India–USAsettledDoes owning an Indian subsidiary itself create a PE?India–USAsettledWhat is the transfer pricing safe harbour floor for software development services?IndiaadministrativeWhat documentation must a non-resident furnish to claim a treaty withholding rate?IndiasettledIs a Tax Residency Certificate sufficient for treaty benefits after Tiger Global?IndiajudicialCan the India–UAE service PE limb be met without physical presence in India?India–UAEjudicialDoes UK Diverted Profits Tax still apply to an avoided-PE arrangement?IndiasettledDoes UK domestic law have a services-only PE head?India–UKsettledHow is the US substantial presence test computed?IndiasettledDoes a US–Canada dependent agent need authority to conclude contracts?USA–CanadasettledWhat is the construction PE threshold between the US and Canada?USA–CanadasettledFrom when does Article V(9) apply, and do pre-2010 days count?USA–CanadasettledWhen does Article V(9) create a services PE between the US and Canada?USA–CanadasettledWhat denominator does 'wholly or almost wholly' use in the India–US securing-orders limb?India–USAagreed_interpretation