https://www.taxtmi.com/highlights?id=52391 Income accrued in India - For the purpose of applying Article 13(5) of the India-Belgium tax treaty two fold conditions are required to be cumulatively satisfied viz. (i). that, the transfer of shares should represent participation of at least 10% in the capital stock of company; and (ii). that, the company whose shares are transferred should be a resident of a contracting state - Unilateral amendment made available in the I.T Act as ‘Explanation 5’ to Sec. 9(1)(i) of the Act, cannot be read into the India-Belgium tax treaty. - AT en-us Tue, 17 Mar 2020 12:55:32 +0530 Tue, 17 Mar 2020 12:55:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=52391 Income accrued in India - For the purpose of applying Article 13(5) of the India-Belgium tax treaty two fold conditions are required to be cumulatively satisfied viz. (i). that, the transfer of shares should represent participation of at least 10% in the capital stock of company; and (ii). that, the company whose shares are transferred should be a resident of a contracting state - Unilateral amendment made available in the I.T Act as ‘Explanation 5’ to Sec. 9(1)(i) of the Act, cannot be read into the India-Belgium tax treaty. - AT Highlights Income Tax Tue, 17 Mar 2020 12:55:32 +0530 https://www.taxtmi.com/highlights?id=52391