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of <h1>ADTA governs tax on dividends and interest from Foreign Currency Convertible Bonds under fiduciary ownership by Overseas Depositary Banks.</h1> The provisions of the Avoidance of Double Taxation Agreement (ADTA) apply to income from dividends and interest on Foreign Currency Convertible Bonds during fiduciary ownership by an Overseas Depositary Bank. When redeemed underlying shares are transferred to a non-resident investor before being sold to resident purchasers, the ADTA between India and the investor's country of residence governs taxation on dividends, interest, or capital gains from these shares. This ensures that income arising from these financial instruments is taxed appropriately, avoiding double taxation in accordance with international agreements.
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