Exchange of Information: expanded mutual tax information sharing and authorised assistance in tax collection under amended protocol. The Protocol amends the India-Austria tax Convention to: confirm both States' taxation rights over immovable property and related capital gains; require minimum head office expense deductions under Article 7 and treat partner profits as taxable in Austria; permit up to a 15 percentage point tax-rate differential under Article 24; replace Article 26 with a broadened Exchange of Information regime subject to secrecy, use limits, and exceptions; and introduce Article 26A obliging mutual assistance in tax collection under specified procedural and enforceability conditions, with OECD Commentaries guiding interpretation and defined entry-into-force and applicability rules.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Exchange of Information: expanded mutual tax information sharing and authorised assistance in tax collection under amended protocol.
The Protocol amends the India-Austria tax Convention to: confirm both States' taxation rights over immovable property and related capital gains; require minimum head office expense deductions under Article 7 and treat partner profits as taxable in Austria; permit up to a 15 percentage point tax-rate differential under Article 24; replace Article 26 with a broadened Exchange of Information regime subject to secrecy, use limits, and exceptions; and introduce Article 26A obliging mutual assistance in tax collection under specified procedural and enforceability conditions, with OECD Commentaries guiding interpretation and defined entry-into-force and applicability rules.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 
Join Channel
TaxTMI 
