Avoidance of double taxation: treaty allocates taxing rights, limits source state withholdings and provides credit and mutual agreement procedures. The Convention allocates taxing rights between India and Ukraine and prescribes relief and cooperation mechanisms to avoid double taxation and prevent fiscal evasion. It defines residency (with tie breaker rules), permanent establishment criteria (including agency and construction-site rules), and source rules for immovable property, business profits, shipping, dividends, interest, royalties and capital gains. It limits withholding taxes for beneficial owners, requires arm's length attribution for associated enterprises, provides a tax credit method for relief, imposes non discrimination, and establishes mutual agreement, information exchange and tax collection assistance procedures.
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.
Avoidance of double taxation: treaty allocates taxing rights, limits source state withholdings and provides credit and mutual agreement procedures.
The Convention allocates taxing rights between India and Ukraine and prescribes relief and cooperation mechanisms to avoid double taxation and prevent fiscal evasion. It defines residency (with tie breaker rules), permanent establishment criteria (including agency and construction-site rules), and source rules for immovable property, business profits, shipping, dividends, interest, royalties and capital gains. It limits withholding taxes for beneficial owners, requires arm's length attribution for associated enterprises, provides a tax credit method for relief, imposes non discrimination, and establishes mutual agreement, information exchange and tax collection assistance procedures.
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