Tax treaty residency scope applies to persons resident in one or both contracting states, enabling avoidance of double taxation. The instrument implements a bilateral Double Taxation Avoidance Agreement between India and the Syrian Arab Republic, effective upon mutual notification and given effect in India under powers conferred by the Income Tax Act and the Companies (Profits) Surtax Act. Article 1 provides that the Agreement applies to persons who are residents of one or both Contracting States, thereby defining the class of taxpayers covered for treaty relief and obligations.
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 residency scope applies to persons resident in one or both contracting states, enabling avoidance of double taxation.
The instrument implements a bilateral Double Taxation Avoidance Agreement between India and the Syrian Arab Republic, effective upon mutual notification and given effect in India under powers conferred by the Income Tax Act and the Companies (Profits) Surtax Act. Article 1 provides that the Agreement applies to persons who are residents of one or both Contracting States, thereby defining the class of taxpayers covered for treaty relief and obligations.
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