Agreement between the Government of the Republic of India and the Government of the People's Republic of China for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes - G.S.R. 331(E) - Income Tax Act, 1961
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Avoidance of double taxation: treaty allocates taxing rights, residence rules, permanent establishment and information exchange protections. Agreement creates a bilateral framework to avoid double taxation and prevent fiscal evasion by allocating taxing rights, defining residents and permanent establishment, and prescribing methods for elimination of double taxation. It specifies source and residence rules across categories of income-business profits, immovable property, shipping and air transport, dividends, interest, royalties, capital gains and personal services-provides non discrimination protections, a mutual agreement procedure for treaty disputes, and confidential exchange of information subject to domestic law limits.
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Provisions expressly mentioned in the judgment/order text.
Avoidance of double taxation: treaty allocates taxing rights, residence rules, permanent establishment and information exchange protections.
Agreement creates a bilateral framework to avoid double taxation and prevent fiscal evasion by allocating taxing rights, defining residents and permanent establishment, and prescribing methods for elimination of double taxation. It specifies source and residence rules across categories of income-business profits, immovable property, shipping and air transport, dividends, interest, royalties, capital gains and personal services-provides non discrimination protections, a mutual agreement procedure for treaty disputes, and confidential exchange of information subject to domestic law limits.
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