Tag Archives: N.V.

Foreign Bank PE Faces Higher Tax, Intra-Entity Interest Adjustments, Computer Depreciation on ATMs, Full Lease Deduction

By | October 10, 2026

Foreign Bank PE Faces Higher Tax, Intra-Entity Interest Adjustments, Computer Depreciation on ATMs, Full Lease Deduction Issue Whether charging a higher tax rate on a foreign bank’s PE violates DTAA non-discrimination rules. Whether interest paid by an Indian PE to its overseas head office is subject to Section 195 TDS and Section 40(a)(i) disallowance. Whether… Read More »