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Applicability of bilateral tax treaties in triangular cases

April 10, 2019[2019] 104 taxmann.com 152 (Article)
Tax treaties are usually entered into between two states and often it is seen that bilateral tax treaties do not always function efficiently in situations where more than two states are involved. These situations are referred to as 'triangular cases' and they arise where a person who is resident in one state and has a permanent establishment (PE) in another state or where a person who is resident in two states for tax purposes (a dual resident), has transactions with a resident of a third state.
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