Convention between the Republic of India and the Republic of Finland for the avoidance of Double Taxation with respect to taxes on income and on capital - 0786(E) - Income Tax Act, 1961
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Avoidance of double taxation allocates taxing rights between contracting states and prescribes relief, PE rules and information exchange. The Convention allocates taxing rights between contracting States for taxes on income and capital, applies to residents, and defines residence tie breakers and key terms. A permanent establishment test (fixed place and agent rules, construction site thresholds) determines business taxing nexus; profits attributable to a permanent establishment are computed as if it were a separate enterprise with prescribed deduction limits. Dividends, interest, royalties and service fees are subject to specified taxing rights and maximum source withholding rates, and double taxation is eliminated by detailed credit or exemption methods. The treaty provides mutual agreement, information exchange, entry into force and termination rules.
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.
Avoidance of double taxation allocates taxing rights between contracting states and prescribes relief, PE rules and information exchange.
The Convention allocates taxing rights between contracting States for taxes on income and capital, applies to residents, and defines residence tie breakers and key terms. A permanent establishment test (fixed place and agent rules, construction site thresholds) determines business taxing nexus; profits attributable to a permanent establishment are computed as if it were a separate enterprise with prescribed deduction limits. Dividends, interest, royalties and service fees are subject to specified taxing rights and maximum source withholding rates, and double taxation is eliminated by detailed credit or exemption methods. The treaty provides mutual agreement, information exchange, entry into force and termination rules.
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