Limitation of benefits permits taxation where treaty limits tax but income is exempt under the other State's domestic law. Article 24 provides that if the Convention limits a Contracting State's right to tax and the income is exempt under the other State's domestic law, the first State may tax that income as if the Convention did not exist; the rule applies reciprocally between India and Namibia.
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.
Limitation of benefits permits taxation where treaty limits tax but income is exempt under the other State's domestic law.
Article 24 provides that if the Convention limits a Contracting State's right to tax and the income is exempt under the other State's domestic law, the first State may tax that income as if the Convention did not exist; the rule applies reciprocally between India and Namibia.
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