Tax treaty interpretations preserve source taxation rights and clarify shipping, interest, nondiscrimination, and information exchange. Protocol to the India-Uruguay DTAA records understandings that preserve resident coverage under Uruguay's territorial-source taxation, treat container rental profits and interest integral to ship or aircraft operations as taxable in the resident State (excluding Article 11 for such interest), affirm source State taxing rights where domestic law could otherwise leave income untaxed, permit higher taxation on profits of a permanent establishment compared with similar domestic companies under non-discrimination, and allow India to share exchanged information for law enforcement and parliamentary purposes, with Article 27 operative for fiscal years beginning the calendar year after entry into force.
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 treaty interpretations preserve source taxation rights and clarify shipping, interest, nondiscrimination, and information exchange.
Protocol to the India-Uruguay DTAA records understandings that preserve resident coverage under Uruguay's territorial-source taxation, treat container rental profits and interest integral to ship or aircraft operations as taxable in the resident State (excluding Article 11 for such interest), affirm source State taxing rights where domestic law could otherwise leave income untaxed, permit higher taxation on profits of a permanent establishment compared with similar domestic companies under non-discrimination, and allow India to share exchanged information for law enforcement and parliamentary purposes, with Article 27 operative for fiscal years beginning the calendar year after entry into force.
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