Double taxation relief: treaty limits source taxation to permanent establishments and mandates residence credit to avoid double taxation. Agreement establishes a bilateral double taxation framework between India and Indonesia, specifying that business profits are taxable in the other State only if a permanent establishment exists and that shipping and air transport income is exempt in the source State. The treaty provides concessional source-country taxation for dividends, interest and royalties and eliminates double taxation by requiring the residence State to allow credit for taxes paid or spared in the source State.
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 relief: treaty limits source taxation to permanent establishments and mandates residence credit to avoid double taxation.
Agreement establishes a bilateral double taxation framework between India and Indonesia, specifying that business profits are taxable in the other State only if a permanent establishment exists and that shipping and air transport income is exempt in the source State. The treaty provides concessional source-country taxation for dividends, interest and royalties and eliminates double taxation by requiring the residence State to allow credit for taxes paid or spared in the source State.
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