Agreement between the Government of India and the Government of Italy for the Avoidance of Double Taxation and the prevention of fiscal evasion with respect to taxes on income - 0608(E) - Income Tax Act, 1961
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Double taxation avoidance: India-Italy treaty allocates taxing rights, permanent establishment rules, withholding limits and mutual relief. Treaty allocates taxing rights between India and Italy, defines residence and permanent establishment, and prescribes taxation rules by income category. Business profits are taxable in the State of the enterprise except insofar as attributable to a PE in the other State; immovable property is taxed where situated; specific rules govern air and shipping, dividends, interest, royalties, capital gains, professional and employment income. Double taxation is relieved primarily by foreign tax credit or deduction; administrative safeguards include non discrimination, mutual agreement procedure, and exchange of information subject to confidentiality and domestic legal limits.
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.
Treaty allocates taxing rights between India and Italy, defines residence and permanent establishment, and prescribes taxation rules by income category. Business profits are taxable in the State of the enterprise except insofar as attributable to a PE in the other State; immovable property is taxed where situated; specific rules govern air and shipping, dividends, interest, royalties, capital gains, professional and employment income. Double taxation is relieved primarily by foreign tax credit or deduction; administrative safeguards include non discrimination, mutual agreement procedure, and exchange of information subject to confidentiality and domestic legal limits.
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