Avoidance of double taxation: treaty allocates taxing rights, limits withholding and provides mutual assistance and information exchange. Treaty between India and Armenia allocates taxing rights for residents and source income, defines residence and place of effective management, and specifies a permanent establishment concept (including a 270 day construction threshold and agent rules) for attributing business profits. It limits withholding taxation on dividends, interest, royalties and fees for technical services where the beneficial owner is resident in the other State, prescribes methods for elimination of double taxation, non discrimination, mutual agreement procedure, exchange of information with confidentiality safeguards, assistance in tax collection, and a limitation of benefits regime to prevent treaty abuse.
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Provisions expressly mentioned in the judgment/order text.
Avoidance of double taxation: treaty allocates taxing rights, limits withholding and provides mutual assistance and information exchange.
Treaty between India and Armenia allocates taxing rights for residents and source income, defines residence and place of effective management, and specifies a permanent establishment concept (including a 270 day construction threshold and agent rules) for attributing business profits. It limits withholding taxation on dividends, interest, royalties and fees for technical services where the beneficial owner is resident in the other State, prescribes methods for elimination of double taxation, non discrimination, mutual agreement procedure, exchange of information with confidentiality safeguards, assistance in tax collection, and a limitation of benefits regime to prevent treaty abuse.
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