Agreement between the Republic of India and the Republic of Indonesia for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income - 77(E) - Income Tax Act, 1961
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Double taxation avoidance: treaty allocates taxing rights between India and Indonesia and provides tax credit mechanisms. The Agreement allocates taxing rights between India and Indonesia for residents and specified taxes, defines residence (with tie breakers) and a comprehensive notion of permanent establishment, prescribes source state taxation rules for categories of income, caps source withholding on dividends, interest and royalties payable to beneficial owners, provides for foreign tax credits limited to the tax attributable to the income, includes associated enterprise/transfer pricing adjustments, and establishes mutual agreement and information exchange procedures subject to confidentiality limits.
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Provisions expressly mentioned in the judgment/order text.
Double taxation avoidance: treaty allocates taxing rights between India and Indonesia and provides tax credit mechanisms.
The Agreement allocates taxing rights between India and Indonesia for residents and specified taxes, defines residence (with tie breakers) and a comprehensive notion of permanent establishment, prescribes source state taxation rules for categories of income, caps source withholding on dividends, interest and royalties payable to beneficial owners, provides for foreign tax credits limited to the tax attributable to the income, includes associated enterprise/transfer pricing adjustments, and establishes mutual agreement and information exchange procedures subject to confidentiality limits.
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