Withholding tax limits on cross-border passive income set by treaty amendments, reducing source taxation under amended convention. The notification modifies the India-France income tax Convention to impose ceilings on source taxation where the recipient is the beneficial owner. It substitutes paragraphs limiting tax at source on dividends, interest and royalties/fees/payments for use of equipment, including transitional distinctions for certain lenders and a later uniform ceiling, and applies paragraph 7 of the Protocol to give effect to lower or more restricted source taxation adopted in India's treaties with OECD third States.
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Provisions expressly mentioned in the judgment/order text.
Withholding tax limits on cross-border passive income set by treaty amendments, reducing source taxation under amended convention.
The notification modifies the India-France income tax Convention to impose ceilings on source taxation where the recipient is the beneficial owner. It substitutes paragraphs limiting tax at source on dividends, interest and royalties/fees/payments for use of equipment, including transitional distinctions for certain lenders and a later uniform ceiling, and applies paragraph 7 of the Protocol to give effect to lower or more restricted source taxation adopted in India's treaties with OECD third States.
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