Agreement between the Government of the Republic of India and Government of Republic of India and the Government of Greece for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes
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Tax Treaty Allocation of Taxing Rights limits cross-border taxation and defines permanent establishment rules and relief mechanisms.
Treaty allocates taxing rights between India and Greece, defining covered taxes and key terms including resident, company and permanent establishment; it limits taxation of enterprise profits to those derived through a permanent establishment and mandates arm's-length attribution. The agreement prescribes source rules for air and shipping income (with a concessionary reduction and credit for shipping), and specifies exclusive source taxation for royalties, dividends, interest, immovable property and capital gains. It includes 183 day temporary presence exceptions for service income, confidentiality-bound exchange of information, a mutual agreement procedure, and mechanisms to eliminate double taxation.