Taxation of dividends: treaty allocates residence and source taxing rights, with specified source tax treatment and deductions. Dividends between India and the United Arab Republic allocate taxing rights to the residence of the distributing company while preserving source taxation: India may tax dividends paid by Indian resident companies to UAR residents; the UAR may tax dividends paid by UAR resident companies to Indian residents, limited to specified taxes deducted at source and, for natural persons, general income tax. Distributions out of the same year's taxable profits may be deducted from the distributing company's industrial and commercial taxable income, but distributions from accumulated reserves are excluded.
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.
Taxation of dividends: treaty allocates residence and source taxing rights, with specified source tax treatment and deductions.
Dividends between India and the United Arab Republic allocate taxing rights to the residence of the distributing company while preserving source taxation: India may tax dividends paid by Indian resident companies to UAR residents; the UAR may tax dividends paid by UAR resident companies to Indian residents, limited to specified taxes deducted at source and, for natural persons, general income tax. Distributions out of the same year's taxable profits may be deducted from the distributing company's industrial and commercial taxable income, but distributions from accumulated reserves are excluded.
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