Double Taxation Agreement allocates taxing rights and provides credits, dispute resolution, and information exchange mechanisms. The Agreement between India and Finland allocates taxing rights and prevents fiscal evasion for taxes on income by defining residence, taxable income scope, and categories of income with detailed source rules. It establishes a permanent establishment standard and attribution rules, limits source taxation of dividends, interest, royalties and fees for technical services (subject to prescribed caps and exceptions), prescribes elimination of double taxation mechanisms via tax credits or deductions, and provides non discrimination, mutual agreement, exchange of information and assistance in tax collection measures. A Protocol clarifies treatment of agricultural income in Finland and a clause to extend favourable India-OECD Member concessions.
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Provisions expressly mentioned in the judgment/order text.
Double Taxation Agreement allocates taxing rights and provides credits, dispute resolution, and information exchange mechanisms.
The Agreement between India and Finland allocates taxing rights and prevents fiscal evasion for taxes on income by defining residence, taxable income scope, and categories of income with detailed source rules. It establishes a permanent establishment standard and attribution rules, limits source taxation of dividends, interest, royalties and fees for technical services (subject to prescribed caps and exceptions), prescribes elimination of double taxation mechanisms via tax credits or deductions, and provides non discrimination, mutual agreement, exchange of information and assistance in tax collection measures. A Protocol clarifies treatment of agricultural income in Finland and a clause to extend favourable India-OECD Member concessions.
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