Persons covered under the India-China tax treaty: residency and fiscal transparency determine entitlement to treaty benefits. Article 1 applies the Agreement to persons who are residents of one or both Contracting States. Income of entities or arrangements treated as wholly fiscally transparent is considered income of a resident only to the extent that it is treated as such for taxation by that State. The Agreement does not otherwise affect a State's taxation of its residents except concerning specified treaty benefits.
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.
Persons covered under the India-China tax treaty: residency and fiscal transparency determine entitlement to treaty benefits.
Article 1 applies the Agreement to persons who are residents of one or both Contracting States. Income of entities or arrangements treated as wholly fiscally transparent is considered income of a resident only to the extent that it is treated as such for taxation by that State. The Agreement does not otherwise affect a State's taxation of its residents except concerning specified treaty benefits.
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