Double taxation avoidance pact limits source state taxation and prescribes residence, PE, and withholding rules between India and Sri Lanka. Bilateral Agreement to avoid double taxation and prevent fiscal evasion between India and Sri Lanka applies to residents of one or both States and taxes on income. It defines residence and permanent establishment rules, allocates taxing rights (immovable property to source State; business profits to residence except profits attributable to a PE in the source State), prescribes withholding ceilings for dividends, interest and royalties/technical services, and provides mechanisms for mutual agreement, exchange of information, assistance in tax collection, limitation of benefits, non discrimination and procedural entry into force and termination rules.
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.
Double taxation avoidance pact limits source state taxation and prescribes residence, PE, and withholding rules between India and Sri Lanka.
Bilateral Agreement to avoid double taxation and prevent fiscal evasion between India and Sri Lanka applies to residents of one or both States and taxes on income. It defines residence and permanent establishment rules, allocates taxing rights (immovable property to source State; business profits to residence except profits attributable to a PE in the source State), prescribes withholding ceilings for dividends, interest and royalties/technical services, and provides mechanisms for mutual agreement, exchange of information, assistance in tax collection, limitation of benefits, non discrimination and procedural entry into force and termination rules.
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