Double Taxation Avoidance Agreement: Between India and the U. S. A.
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Reciprocal exemption for international shipping and aviation income exempts qualifying residents and corporations from foreign tax obligations.
A reciprocal exemption exempts residents and qualifying corporations of each Contracting State from tax on gross income from the international operation of ships and aircraft in the other State, subject to a corporate ownership test (over 50% resident ownership or equivalent reciprocal treatment) or a market trading test, with gross income defined to include rentals, bareboat charters, container rentals, pool participation income, interest linked to operations, and gains on disposition; the agreement amends the 1976 treaty and is effective for taxable years beginning on or after January 1, 1987.