Government income exemption under tax treaty protects non commercial dividends, interest and other non commercial gains from source taxation. Income derived by the Government of a Contracting State from sources within the other State is exempt from tax there, covering dividends under Article 10, interest under Article 11, and other income or gains from transactions not pursuant to commercial activities; Government is defined to include each State's government and specified non commercial statutory bodies and institutions, with further bodies includable by agreement of the competent authorities.
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.
Government income exemption under tax treaty protects non commercial dividends, interest and other non commercial gains from source taxation.
Income derived by the Government of a Contracting State from sources within the other State is exempt from tax there, covering dividends under Article 10, interest under Article 11, and other income or gains from transactions not pursuant to commercial activities; Government is defined to include each State's government and specified non commercial statutory bodies and institutions, with further bodies includable by agreement of the competent authorities.
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