Tax treaty amendments tighten royalties limits, expand information exchange and add anti abuse rules on share gains. The Protocols amend the India-Singapore tax treaty to: cap source taxation of royalties and technical service fees at 10% for beneficial owners (2005 Protocol); expand Exchange of Information obligations to require foreseeably relevant information exchange and maintain secrecy and use limits (2011 Protocol); and (Third Protocol, effective 2017) require associated enterprise adjustments, modify taxation of capital gains on shares with transitional rules, institute anti-abuse rules denying benefits to arrangements or entities structured to obtain treaty advantages and define shell/conduit tests and exceptions.
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Tax treaty amendments tighten royalties limits, expand information exchange and add anti abuse rules on share gains.
The Protocols amend the India-Singapore tax treaty to: cap source taxation of royalties and technical service fees at 10% for beneficial owners (2005 Protocol); expand Exchange of Information obligations to require foreseeably relevant information exchange and maintain secrecy and use limits (2011 Protocol); and (Third Protocol, effective 2017) require associated enterprise adjustments, modify taxation of capital gains on shares with transitional rules, institute anti-abuse rules denying benefits to arrangements or entities structured to obtain treaty advantages and define shell/conduit tests and exceptions.
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