Faceless reassessment jurisdiction turned on retrospective AO definition, with later faceless-assessment changes treated as clarificatory and procedur...
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The notification, issued by the Ministry of Finance, pertains to the modification of the Convention between the Government of India and the Kingdom of Spain for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income and on capital. It addresses the taxation of royalties and fees for technical services between the two countries. Specifically, it substitutes paragraph 2 of Article 13 of the Convention, limiting the taxation at source on royalties and fees for technical services to ten per cent of the gross amount, provided the recipient is the beneficial owner.
The notification, issued by the Ministry of Finance, pertains to the modification of the Convention between the Government of India and the Kingdom of Spain for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income and on capital. It addresses the taxation of royalties and fees for technical services between the two countries. Specifically, it substitutes paragraph 2 of Article 13 of the Convention, limiting the taxation at source on royalties and fees for technical services to ten per cent of the gross amount, provided the recipient is the beneficial owner.
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