Amending the Agreement between the Government of the Republic of India and the Government of the Swiss Federal Council u/s 90 - 35 - Income Tax Act, 1961
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Double taxation avoidance amendments: Protocol limits source taxation and updates permanent establishment and service taxation rules. The Central Government, under section 90, gives effect to the Protocol amending the India-Switzerland Double Taxation Agreement. The Protocol revises definitions (expanding 'India'), updates permanent establishment rules to capture technical services and certain insurance activities, inserts transfer pricing adjustment and consultation obligations, limits source taxation of dividends, interest, royalties and technical service fees when paid to beneficial owners resident in the other State (subject to PE/fixed base exceptions), revises capital gains and personal services provisions, and sets entry into force and effective fiscal year dates.
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Double taxation avoidance amendments: Protocol limits source taxation and updates permanent establishment and service taxation rules.
The Central Government, under section 90, gives effect to the Protocol amending the India-Switzerland Double Taxation Agreement. The Protocol revises definitions (expanding "India"), updates permanent establishment rules to capture technical services and certain insurance activities, inserts transfer pricing adjustment and consultation obligations, limits source taxation of dividends, interest, royalties and technical service fees when paid to beneficial owners resident in the other State (subject to PE/fixed base exceptions), revises capital gains and personal services provisions, and sets entry into force and effective fiscal year dates.
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