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        Case ID :

        Agreement for Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to taxes on income between India and Myanmar to be effective from 1-04-2010 - 49/2009 - Income Tax Act, 1961

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        Double taxation avoidance between India and Myanmar: residence, permanent establishment rules and reduced source taxation for dividends, interest, royalties. Agreement sets rules to prevent double taxation between India and Myanmar: it applies to residents and taxes on income, defines residence tie-breakers, treats business profits as taxable in the resident State except for profits attributable to a permanent establishment in the source State (with arm's-length attribution and specified deductions), caps source taxation of dividends, interest and royalties when the beneficial owner is a resident of the other State, provides methods for elimination of double taxation by credits limited to the tax attributable to foreign-source income, establishes mutual agreement and exchange-of-information procedures, non-discrimination, a limitation-of-benefits rule, and entry-into-force and termination provisions, with a Protocol clarifying construction-site thresholds, profit attribution rules and future reviews of certain articles.
                      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 avoidance between India and Myanmar: residence, permanent establishment rules and reduced source taxation for dividends, interest, royalties.

                            Agreement sets rules to prevent double taxation between India and Myanmar: it applies to residents and taxes on income, defines residence tie-breakers, treats business profits as taxable in the resident State except for profits attributable to a permanent establishment in the source State (with arm's-length attribution and specified deductions), caps source taxation of dividends, interest and royalties when the beneficial owner is a resident of the other State, provides methods for elimination of double taxation by credits limited to the tax attributable to foreign-source income, establishes mutual agreement and exchange-of-information procedures, non-discrimination, a limitation-of-benefits rule, and entry-into-force and termination provisions, with a Protocol clarifying construction-site thresholds, profit attribution rules and future reviews of certain articles.





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                            ActsIncome Tax
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