Agreement between the Government of the Republic of India and the Government of the German Democratic Republic for the avoidance of double taxation with respect to taxes on income and on capital
Show AI Summary
Double taxation avoidance treaty allocates taxing rights, limits source withholding and provides MAP, information exchange and collection assistance.
Bilateral agreement governs avoidance of double taxation between India and the German Democratic Republic, applying to residents and specified taxes (Indian income and wealth taxes; specified GDR income, corporate and property taxes and similar successor taxes). It allocates taxing rights for business profits to the State of residence unless business is carried on through a permanent establishment in the other State, prescribes methods for attributing profits to such establishments, caps source withholding on dividends, interest and royalties for beneficial owners, allocates capital gains taxation by type, and provides non-discrimination, mutual agreement, exchange of information and assistance in collection mechanisms.