Avoidance of double taxation: treaty allocates taxing rights and establishes exchange, dispute and anti abuse mechanisms between the States. The India-Albania tax treaty allocates taxing rights on income and capital between residents of the two States, defines resident status and permanent establishment, and prescribes taxing rules for immovable property, business profits, international transport, dividends, interest, royalties, capital gains and personal services. It provides methods for elimination of double taxation by credit/deduction, non discrimination protections, a mutual agreement procedure for disputes, comprehensive exchange of information with confidentiality safeguards, assistance in tax collection, and a Limitation of Benefits anti abuse rule.
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Provisions expressly mentioned in the judgment/order text.
Avoidance of double taxation: treaty allocates taxing rights and establishes exchange, dispute and anti abuse mechanisms between the States.
The India-Albania tax treaty allocates taxing rights on income and capital between residents of the two States, defines resident status and permanent establishment, and prescribes taxing rules for immovable property, business profits, international transport, dividends, interest, royalties, capital gains and personal services. It provides methods for elimination of double taxation by credit/deduction, non discrimination protections, a mutual agreement procedure for disputes, comprehensive exchange of information with confidentiality safeguards, assistance in tax collection, and a Limitation of Benefits anti abuse rule.
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