Avoidance of double taxation: treaty allocates taxing rights, limits source taxation and provides cooperation measures between the States. The Agreement establishes a bilateral framework to avoid double taxation and prevent fiscal evasion between India and Mozambique, applies to residents and taxes on income, and defines residence, permanent establishment (including inclusions, exclusions and time thresholds), and allocation of taxing rights for business profits, dividends, interest, royalties and capital gains. It provides relief by tax credit/deduction rules, a mutual agreement procedure, exchange of information, assistance in tax collection, non discrimination protections and a limitation of benefits anti abuse rule. The Government of India notified the Agreement shall be given effect in India from 1 April 2012.
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 taxation and provides cooperation measures between the States.
The Agreement establishes a bilateral framework to avoid double taxation and prevent fiscal evasion between India and Mozambique, applies to residents and taxes on income, and defines residence, permanent establishment (including inclusions, exclusions and time thresholds), and allocation of taxing rights for business profits, dividends, interest, royalties and capital gains. It provides relief by tax credit/deduction rules, a mutual agreement procedure, exchange of information, assistance in tax collection, non discrimination protections and a limitation of benefits anti abuse rule. The Government of India notified the Agreement shall be given effect in India from 1 April 2012.
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