CONVENTION BETWEEN THE GOVERNMENT OF THE REPUBLIC OF INDIA AND THE GOVERNMENT OF THE KINGDOM OF SAUDI ARABIA FOR THE AVOIDANCE OF DOUBLE TAXATION-DTAA COMES INTO EFFECT FROM 1-11-06
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Avoidance of double taxation: India-Saudi DTAA sets PE, residence tie breaker, withholding limits and information exchange rules.
The Convention provides a bilateral framework for the avoidance of double taxation and prevention of tax evasion between India and Saudi Arabia, to be applied in India under section 90 of the Income tax Act. It defines persons and taxes covered, residence and tie breaker rules, a detailed permanent establishment regime (including inclusions, exclusions and agency rules), allocation and limitation rules for categories of income (business profits, dividends, interest, royalties, capital gains, employment income, artistes, pensions), methods to eliminate double taxation, a Mutual Agreement Procedure and Exchange of Information safeguards, anti abuse provisions, and entry into force, application and termination mechanics; the Protocol clarifies Zakat treatment and other interpretive points.