https://www.taxtmi.com/circulars?id=2867 A Certificate of Residence issued by Mauritian authorities is sufficient evidence of both residence and beneficial ownership for applying the Indo Mauritius DTAC to dividends and capital gains; Mauritius resident FIIs and funds incorporated and taxable in Mauritius are treated as residents and, accordingly, not taxable in India on capital gains from sale of shares under Article 13. Where an entity is resident of both States, paragraph 3 of Article 4 deems it resident in the State of its place of effective management, permitting Assessing Officers to determine residence on the facts. en-us Mon, 10 Feb 2003 00:00:00 +0530 Mon, 11 Aug 2008 10:28:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/circulars?id=2867 A Certificate of Residence issued by Mauritian authorities is sufficient evidence of both residence and beneficial ownership for applying the Indo Mauritius DTAC to dividends and capital gains; Mauritius resident FIIs and funds incorporated and taxable in Mauritius are treated as residents and, accordingly, not taxable in India on capital gains from sale of shares under Article 13. Where an entity is resident of both States, paragraph 3 of Article 4 deems it resident in the State of its place of effective management, permitting Assessing Officers to determine residence on the facts. Circulars Income Tax Mon, 10 Feb 2003 00:00:00 +0530 https://www.taxtmi.com/circulars?id=2867