Tax Residence Rule: temporary residence test for individuals determining taxation between contracting states under DTAA. The Protocol defines tax as the Slovenian or Indian tax excluding penalties and interest, and fixes fiscal year as the calendar year for Slovenia and the financial year beginning 1 April for India. It permits both Contracting States to tax income from immovable property and related capital gains subject to the Convention, deems an individual resident for the fiscal year of visit or the immediately preceding fiscal year for residence purposes, and allows higher domestic taxation of profits attributable to a permanent establishment up to a fifteen percentage point differential.
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.
Tax Residence Rule: temporary residence test for individuals determining taxation between contracting states under DTAA.
The Protocol defines tax as the Slovenian or Indian tax excluding penalties and interest, and fixes fiscal year as the calendar year for Slovenia and the financial year beginning 1 April for India. It permits both Contracting States to tax income from immovable property and related capital gains subject to the Convention, deems an individual resident for the fiscal year of visit or the immediately preceding fiscal year for residence purposes, and allows higher domestic taxation of profits attributable to a permanent establishment up to a fifteen percentage point differential.
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