Agreement between the Government of India and the Government of the United Arab Republic for the avoidance of double taxation - 2363 - Income Tax Act, 1961
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Avoidance of double taxation: treaty allocates taxing rights, PE attribution, and methods to eliminate double taxation for residents. Convention between India and the United Arab Republic to avoid double taxation on income: applies to residents and taxes on income (including successor similar taxes); defines residence, company, enterprise and competent authority; establishes a permanent establishment concept with inclusions/exclusions and agent rules; allocates taxation of business profits to the State of residence unless attributable to a PE in the other State and prescribes profit attribution principles; treats immovable property, capital gains, dividends, interest, royalties and specific personal service categories with distinct taxing rights; provides exemption or credit methods to eliminate double taxation; mandates mutual agreement procedures and exchange of information; includes entry into force, transitional provisions for air transport 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.
Avoidance of double taxation: treaty allocates taxing rights, PE attribution, and methods to eliminate double taxation for residents.
Convention between India and the United Arab Republic to avoid double taxation on income: applies to residents and taxes on income (including successor similar taxes); defines residence, company, enterprise and competent authority; establishes a permanent establishment concept with inclusions/exclusions and agent rules; allocates taxation of business profits to the State of residence unless attributable to a PE in the other State and prescribes profit attribution principles; treats immovable property, capital gains, dividends, interest, royalties and specific personal service categories with distinct taxing rights; provides exemption or credit methods to eliminate double taxation; mandates mutual agreement procedures and exchange of information; includes entry into force, transitional provisions for air transport and termination rules.
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