Double taxation treaty: clarifies taxation of immovable property, partnerships, head office deductions, rate differentials and data confidentiality. The Protocol clarifies that income from immovable property and capital gains on its alienation in India may be taxed in both Contracting States; guarantees a minimum level of head office expense deductions for India; treats partner shares and sleeping partnerships as profits in Austria; permits higher tax rates on profits of a foreign permanent establishment relative to similar domestic companies within a capped differential; and restricts waiver of confidentiality in information exchange to protect predominant legitimate interests and recognised basic data protection rights.
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.
Double taxation treaty: clarifies taxation of immovable property, partnerships, head office deductions, rate differentials and data confidentiality.
The Protocol clarifies that income from immovable property and capital gains on its alienation in India may be taxed in both Contracting States; guarantees a minimum level of head office expense deductions for India; treats partner shares and sleeping partnerships as profits in Austria; permits higher tax rates on profits of a foreign permanent establishment relative to similar domestic companies within a capped differential; and restricts waiver of confidentiality in information exchange to protect predominant legitimate interests and recognised basic data protection rights.
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