Double taxation avoidance: treaty allocates taxing rights, provides credit relief, residency tie breakers and information exchange. The Agreement between India and Malaysia allocates taxing rights for residents, defines residency and permanent establishment rules, prescribes attribution of business profits to permanent establishments on an arm's length basis, and sets sectoral rules for immovable property, shipping, air transport, dividends, interest, royalties, employment income and other specific categories. It requires mutual agreement procedures for disputes, mandates exchange of information subject to confidentiality and legal limits, provides for tax credits to eliminate double taxation with rules for treatment of special incentive measures, and establishes entry into force, termination and a shipping protocol.
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: treaty allocates taxing rights, provides credit relief, residency tie breakers and information exchange.
The Agreement between India and Malaysia allocates taxing rights for residents, defines residency and permanent establishment rules, prescribes attribution of business profits to permanent establishments on an arm's length basis, and sets sectoral rules for immovable property, shipping, air transport, dividends, interest, royalties, employment income and other specific categories. It requires mutual agreement procedures for disputes, mandates exchange of information subject to confidentiality and legal limits, provides for tax credits to eliminate double taxation with rules for treatment of special incentive measures, and establishes entry into force, termination and a shipping protocol.
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