Agreement between the Government of the Republic of India and the Government of the Republic of Italy for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes - G.S.R. 189 (E) - Income Tax Act, 1961
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Double taxation relief: Convention allocates taxing rights, limits source taxation and provides credits plus dispute resolution mechanisms. Convention allocates taxing rights between India and Italy, applies to residents and specified taxes, and defines key terms including tax residence and enterprise. It establishes the permanent establishment criterion with inclusions, exclusions and profit attribution on an arm's length basis; allocates taxation for immovable property, business profits, air and shipping, dividends, interest, royalties, capital gains and personal services; and prescribes elimination of double taxation by credit or deduction, a mutual agreement procedure for disputes, and an exchange of information mechanism, with a protocol clarifying reservations and entry into force provisions.
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.
Double taxation relief: Convention allocates taxing rights, limits source taxation and provides credits plus dispute resolution mechanisms.
Convention allocates taxing rights between India and Italy, applies to residents and specified taxes, and defines key terms including tax residence and enterprise. It establishes the permanent establishment criterion with inclusions, exclusions and profit attribution on an arm's length basis; allocates taxation for immovable property, business profits, air and shipping, dividends, interest, royalties, capital gains and personal services; and prescribes elimination of double taxation by credit or deduction, a mutual agreement procedure for disputes, and an exchange of information mechanism, with a protocol clarifying reservations and entry into force provisions.
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