Double taxation agreement establishes withholding ceilings and allocation rules to prevent double taxation and fiscal evasion. India and Malta concluded an agreement to avoid double taxation and prevent fiscal evasion, covering residents and taxes on income, with defined residence and permanent establishment rules, allocation of taxing rights across income categories, and mechanisms for eliminating double taxation through deductions or foreign tax credits. The treaty imposes withholding ceilings for dividends, interest, royalties and technical service fees for beneficial owners, provides non discrimination, mutual agreement and exchange of information procedures, includes a limitation of benefits rule to curb treaty shopping, and a Protocol clarifying Malta's imputation system and certain fiscal regime exemptions.
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Provisions expressly mentioned in the judgment/order text.
Double taxation agreement establishes withholding ceilings and allocation rules to prevent double taxation and fiscal evasion.
India and Malta concluded an agreement to avoid double taxation and prevent fiscal evasion, covering residents and taxes on income, with defined residence and permanent establishment rules, allocation of taxing rights across income categories, and mechanisms for eliminating double taxation through deductions or foreign tax credits. The treaty imposes withholding ceilings for dividends, interest, royalties and technical service fees for beneficial owners, provides non discrimination, mutual agreement and exchange of information procedures, includes a limitation of benefits rule to curb treaty shopping, and a Protocol clarifying Malta's imputation system and certain fiscal regime exemptions.
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