Avoidance of double taxation: treaty sets residence, permanent establishment rules and withholding limits to allocate taxing rights. Notification under section 90 gives effect in India from 1 April 2014 to the India-Latvia Agreement for avoidance of double taxation. The Agreement applies to residents and taxes on income, defines key terms and fiscal years, prescribes residence tie breaker rules, and establishes a comprehensive permanent establishment definition with activity based thresholds and profit attribution rules. It allocates taxing rights for immovable property, business profits, shipping, dividends, interest and royalties (subject to source state withholding limits), provides methods for elimination of double taxation, and contains mutual agreement, information exchange, collection assistance and limitation of benefits provisions.
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.
Avoidance of double taxation: treaty sets residence, permanent establishment rules and withholding limits to allocate taxing rights.
Notification under section 90 gives effect in India from 1 April 2014 to the India-Latvia Agreement for avoidance of double taxation. The Agreement applies to residents and taxes on income, defines key terms and fiscal years, prescribes residence tie breaker rules, and establishes a comprehensive permanent establishment definition with activity based thresholds and profit attribution rules. It allocates taxing rights for immovable property, business profits, shipping, dividends, interest and royalties (subject to source state withholding limits), provides methods for elimination of double taxation, and contains mutual agreement, information exchange, collection assistance and limitation of benefits provisions.
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