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Indian ruling that US pension fund does not qualify for treaty benefits

|Treaty Development|India-United States
India-United States

The Indian Authority for Advance Rulings (AAR) has issued a ruling dated 20 December 2005, in an application made by the General Electric Pension Trust (GEPT), that GEPT was not entitled to the benefits of the India-United States tax treaty (the tax treaty) as it was not liable to tax in the United States and therefore, cannot be treated as a US tax resident for purposes of US taxation and …

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