Convention between the Government of the Republic of India and the Government of the Socialist Republic of Romania for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income - 80(E) - Income Tax Act, 1961
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Avoidance of double taxation: treaty allocates taxing rights, limits source withholding and mandates information exchange to prevent evasion. Bilateral Convention provides a framework to avoid double taxation and prevent fiscal evasion between India and Romania by allocating taxing rights across income categories, defining residence and permanent establishment criteria (including inclusions, exclusions and a construction threshold), limiting source state withholding on dividends, interest, commission, royalties and fees for technical services, prescribing profit attribution and deduction rules for permanent establishments, and securing relief through a credit mechanism together with non discrimination, mutual agreement procedures, exchange of information and assistance in tax collection.
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: treaty allocates taxing rights, limits source withholding and mandates information exchange to prevent evasion.
Bilateral Convention provides a framework to avoid double taxation and prevent fiscal evasion between India and Romania by allocating taxing rights across income categories, defining residence and permanent establishment criteria (including inclusions, exclusions and a construction threshold), limiting source state withholding on dividends, interest, commission, royalties and fees for technical services, prescribing profit attribution and deduction rules for permanent establishments, and securing relief through a credit mechanism together with non discrimination, mutual agreement procedures, exchange of information and assistance in tax collection.
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