Partnership residency under DTAA: treaty benefits apply where partnership income is taxed as resident in that contracting state. The India UK DTAA amendment removed the exclusion of UK partnership firms and provides that for partnerships, estates or trusts the term 'resident of a Contracting State' applies only to the extent the income is subject to tax in that State as the income of a resident, either in the hands of the entity or in the hands of its partners or beneficiaries. The Central Board clarifies the DTAA applies to a partnership resident of either India or the UK only to that extent.
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.
Partnership residency under DTAA: treaty benefits apply where partnership income is taxed as resident in that contracting state.
The India UK DTAA amendment removed the exclusion of UK partnership firms and provides that for partnerships, estates or trusts the term "resident of a Contracting State" applies only to the extent the income is subject to tax in that State as the income of a resident, either in the hands of the entity or in the hands of its partners or beneficiaries. The Central Board clarifies the DTAA applies to a partnership resident of either India or the UK only to that extent.
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