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Section 90 of the Income-tax Act, 1961 - Double Taxation Agreement - Agreement for Avoidance of Double Taxation and Prevention of Fiscal Evasion with foreign countries - With Slovenia - 157/2005 - Income Tax Act, 1961
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Double taxation agreement allocates taxing rights, limits source taxation and provides credit relief plus information exchange. Bilateral Convention between India and Slovenia allocates taxing rights on various categories of income, defines residence and permanent establishment (with inclusions, exclusions and a 12 month construction threshold), and limits source taxation of business profits to amounts attributable to a permanent establishment. Dividends, interest and royalties may be taxed by the source State subject to specified withholding caps; immovable property and certain capital gains may be taxed where situated. Double taxation is eliminated principally by allowing a credit for tax paid in the other State. The treaty provides non discrimination, a mutual agreement procedure and exchange of information obligations.
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Provisions expressly mentioned in the judgment/order text.
Double taxation agreement allocates taxing rights, limits source taxation and provides credit relief plus information exchange.
Bilateral Convention between India and Slovenia allocates taxing rights on various categories of income, defines residence and permanent establishment (with inclusions, exclusions and a 12 month construction threshold), and limits source taxation of business profits to amounts attributable to a permanent establishment. Dividends, interest and royalties may be taxed by the source State subject to specified withholding caps; immovable property and certain capital gains may be taxed where situated. Double taxation is eliminated principally by allowing a credit for tax paid in the other State. The treaty provides non discrimination, a mutual agreement procedure and exchange of information obligations.
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