Agreement between the Government of the Republic of India and the Government of Republic of Cyprus for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes - 3/2017 - Income Tax Act, 1961
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Avoidance of double taxation: treaty allocates taxing rights, limits source taxation and mandates information exchange. Agreement between India and Cyprus allocates taxing rights to prevent double taxation and fiscal evasion: residents are covered; taxes on income and similar future taxes apply; immovable property is taxable at source; business profits are taxable at the residence state unless attributable to a permanent establishment in the source state with rules for profit attribution and limited intra-group deductions; specific rules govern dividends, interest, royalties, capital gains, personal services, non-discrimination, elimination of double taxation, mutual agreement procedure, exchange of information and mutual assistance in collection, with a protocol addressing transitional and interpretative clarifications.
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 allocates taxing rights, limits source taxation and mandates information exchange.
Agreement between India and Cyprus allocates taxing rights to prevent double taxation and fiscal evasion: residents are covered; taxes on income and similar future taxes apply; immovable property is taxable at source; business profits are taxable at the residence state unless attributable to a permanent establishment in the source state with rules for profit attribution and limited intra-group deductions; specific rules govern dividends, interest, royalties, capital gains, personal services, non-discrimination, elimination of double taxation, mutual agreement procedure, exchange of information and mutual assistance in collection, with a protocol addressing transitional and interpretative clarifications.
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