Avoidance of double taxation treaty allocates taxing rights and sets residency, PE, exchange of information and anti abuse rules. The Agreement provides a bilateral framework to avoid double taxation and prevent fiscal evasion between India and Estonia, defining scope, residency and tie breaker rules, and specifying a detailed permanent establishment definition with activity thresholds. It allocates taxing rights for business profits, immovable property, shipping, dividends, interest, royalties and capital gains; prescribes reciprocal methods for eliminating double taxation; establishes mutual agreement and information exchange procedures; includes assistance in tax collection; and contains limitation of benefits anti abuse provisions and entry into force rules.
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 and sets residency, PE, exchange of information and anti abuse rules.
The Agreement provides a bilateral framework to avoid double taxation and prevent fiscal evasion between India and Estonia, defining scope, residency and tie breaker rules, and specifying a detailed permanent establishment definition with activity thresholds. It allocates taxing rights for business profits, immovable property, shipping, dividends, interest, royalties and capital gains; prescribes reciprocal methods for eliminating double taxation; establishes mutual agreement and information exchange procedures; includes assistance in tax collection; and contains limitation of benefits anti abuse provisions and entry into force rules.
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