Double taxation avoidance: treaty allocates taxing rights and provides tax credit relief to prevent double taxation. Treaty gives effect to bilateral rules allocating taxing rights by income category and preventing fiscal evasion: residence and tie breaker rules determine fiscal domicile; permanent establishment rules and agency provisions govern business taxation and attribution of profits on an arm's length basis; source taxation is defined for immovable property, business profits, dividends, interest, royalties and special categories of income; double taxation is relieved by a tax credit mechanism subject to proportional limits and deeming provisions; non discrimination, mutual agreement procedure and exchange of information provisions support administration and dispute resolution.
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 and provides tax credit relief to prevent double taxation.
Treaty gives effect to bilateral rules allocating taxing rights by income category and preventing fiscal evasion: residence and tie breaker rules determine fiscal domicile; permanent establishment rules and agency provisions govern business taxation and attribution of profits on an arm's length basis; source taxation is defined for immovable property, business profits, dividends, interest, royalties and special categories of income; double taxation is relieved by a tax credit mechanism subject to proportional limits and deeming provisions; non discrimination, mutual agreement procedure and exchange of information provisions support administration and dispute resolution.
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