Protocol Amend the Convention between the Government of the United Kingdom of Great Britain and Northern Ireland and the Government of the Republic of India for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and capital gains - Protocol - Income Tax Act, 1961
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Tax Treaty Amendments clarify residency, dividend withholding limits, information exchange, and cross-border tax collection assistance. Amendments revise definitions and residency to base residence on liability to tax under domestic criteria while excluding persons taxed only on source income and limiting partnership/trust application; restructure dividends to allow recipient state taxation with capped source state withholding for beneficial owners resident in the other State and special treatment for certain investment vehicles; delete the partnerships article; expand exchange of information and add provisions for tax examinations abroad, assistance in collection of revenue claims, and a limitation of benefits clause to deny treaty advantages when a principal purpose is obtaining them.
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.
Tax Treaty Amendments clarify residency, dividend withholding limits, information exchange, and cross-border tax collection assistance.
Amendments revise definitions and residency to base residence on liability to tax under domestic criteria while excluding persons taxed only on source income and limiting partnership/trust application; restructure dividends to allow recipient state taxation with capped source state withholding for beneficial owners resident in the other State and special treatment for certain investment vehicles; delete the partnerships article; expand exchange of information and add provisions for tax examinations abroad, assistance in collection of revenue claims, and a limitation of benefits clause to deny treaty advantages when a principal purpose is obtaining them.
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