U/s 90 of the IT Act, 1961 - Double Taxation Agreement - Amendment of Agreement for Avoidance of Double Taxation and Prevention of Fiscal Evasion with foreign countries - Swiss Confederation. - 62/2011 - Income Tax Act, 1961
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Double taxation amendment strengthens exchange of information and limits source taxation, refining rules for transport enterprises and conduit abuse. The Protocol amends the bilateral tax Agreement by redefining international traffic, limiting taxation of enterprise profits to the State of residence except for amounts attributable to a permanent establishment in the other State, consolidating shipping and air transport profits to the residence State, restricting source taxation of interest and capital gains connected to international transport, and enhancing exchange of information through foreseeably relevant requests, confidentiality safeguards, procedural requirements to prevent fishing expeditions, enforceability of information from financial institutions, and preservation of taxpayers' procedural rights.
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Double taxation amendment strengthens exchange of information and limits source taxation, refining rules for transport enterprises and conduit abuse.
The Protocol amends the bilateral tax Agreement by redefining international traffic, limiting taxation of enterprise profits to the State of residence except for amounts attributable to a permanent establishment in the other State, consolidating shipping and air transport profits to the residence State, restricting source taxation of interest and capital gains connected to international transport, and enhancing exchange of information through foreseeably relevant requests, confidentiality safeguards, procedural requirements to prevent fishing expeditions, enforceability of information from financial institutions, and preservation of taxpayers' procedural rights.
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