Convention between the Govt. of India and the Govt. of the United Kingdom of Great Britain and Northern Ireland for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income and capital gains - 0612(E) - Income Tax Act, 1961
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Double taxation avoidance: bilateral rules allocate taxing rights, limit source withholding, and provide mutual resolution mechanisms. Convention allocates taxing rights between India and the United Kingdom to avoid double taxation and fiscal evasion for income and capital gains, defining residence, permanent establishment, and source allocation rules; prescribes attribution of profits to permanent establishments, reduced source withholding ceilings for dividends, interest, royalties and fees for technical services when paid to beneficial owners resident in the other State; provides non discrimination, mutual agreement and exchange of information mechanisms; and sets entry into force and termination rules, with domestic effect directed under the specified national statutes.
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: bilateral rules allocate taxing rights, limit source withholding, and provide mutual resolution mechanisms.
Convention allocates taxing rights between India and the United Kingdom to avoid double taxation and fiscal evasion for income and capital gains, defining residence, permanent establishment, and source allocation rules; prescribes attribution of profits to permanent establishments, reduced source withholding ceilings for dividends, interest, royalties and fees for technical services when paid to beneficial owners resident in the other State; provides non discrimination, mutual agreement and exchange of information mechanisms; and sets entry into force and termination rules, with domestic effect directed under the specified national statutes.
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