Double Taxation Agreement allocates taxing rights and sets cooperation, anti abuse and dispute resolution mechanisms between India and Ethiopia. The Agreement allocates taxing rights between India and Ethiopia for residents and taxes on income, defines residence and permanent establishment (including thresholds and exclusions), and prescribes how business profits, immovable property, shipping, dividends, interest, royalties, capital gains and personal service income are taxed. It provides methods to eliminate double taxation, non discrimination and anti abuse rules, a limitation of benefits clause, and administrative cooperation measures including mutual agreement procedures, exchange of information with confidentiality limits, and assistance in collection; entry into force and termination rules establish temporal effect.
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Provisions expressly mentioned in the judgment/order text.
Double Taxation Agreement allocates taxing rights and sets cooperation, anti abuse and dispute resolution mechanisms between India and Ethiopia.
The Agreement allocates taxing rights between India and Ethiopia for residents and taxes on income, defines residence and permanent establishment (including thresholds and exclusions), and prescribes how business profits, immovable property, shipping, dividends, interest, royalties, capital gains and personal service income are taxed. It provides methods to eliminate double taxation, non discrimination and anti abuse rules, a limitation of benefits clause, and administrative cooperation measures including mutual agreement procedures, exchange of information with confidentiality limits, and assistance in collection; entry into force and termination rules establish temporal effect.
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