Double taxation avoidance: treaty allocates taxing rights and limits source state withholding to reduce cross border double taxation. Convention allocates taxing rights between India and Sri Lanka to avoid double taxation and prevent fiscal evasion for taxes on income and capital, applying to residents of one or both States and specified taxes. It defines residence and permanent establishment (including inclusions/exclusions and time thresholds), prescribes source state taxation rules for business profits attributable to a PE, sets withholding ceilings for dividends, interest and royalties with exceptions, allocates capital gains taxation by type, and provides relief by foreign tax credit, non discrimination, mutual agreement procedures and exchange of information safeguards.
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 limits source state withholding to reduce cross border double taxation.
Convention allocates taxing rights between India and Sri Lanka to avoid double taxation and prevent fiscal evasion for taxes on income and capital, applying to residents of one or both States and specified taxes. It defines residence and permanent establishment (including inclusions/exclusions and time thresholds), prescribes source state taxation rules for business profits attributable to a PE, sets withholding ceilings for dividends, interest and royalties with exceptions, allocates capital gains taxation by type, and provides relief by foreign tax credit, non discrimination, mutual agreement procedures and exchange of information safeguards.
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