A Special Bench of the Indian Income Tax Appellate Tribunal (ITAT) delivered a ruling dated 22 August 2005 in the case of ABN Amro Bank Nv v. Assistant Director of Income Tax (unreported) on whether interest payments by an Indian branch to its Netherlands head-office were a tax deductible expenditure under the India-Netherlands tax treaty (the tax treaty). (a) Facts. The taxpayer (i.e. ABN Amro Bank Nv), a Netherlands-based bank, had a branch in India. The Indian branch, which constituted a "permanent establishment" (PE) in India under Art. 5 of the tax treaty, had a running account with its Netherlands...