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    <title>2010 (10) TMI 1259 - ITAT MUMBAI</title>
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    <description>&quot;Liable to tax&quot; under the Indo-UAE tax treaty includes a person on whom the other Contracting State has a taxing right by reason of residence, domicile, place of management, place of incorporation or a similar criterion, even if that right is not actually exercised. Actual payment of tax in the UAE is therefore not a for treaty entitlement. The later protocol was noted as confirming that treaty benefits are not contingent on proof of actual dual taxation. On that basis, a UAE resident was treated as entitled to protection under the agreement.</description>
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      <description>&quot;Liable to tax&quot; under the Indo-UAE tax treaty includes a person on whom the other Contracting State has a taxing right by reason of residence, domicile, place of management, place of incorporation or a similar criterion, even if that right is not actually exercised. Actual payment of tax in the UAE is therefore not a for treaty entitlement. The later protocol was noted as confirming that treaty benefits are not contingent on proof of actual dual taxation. On that basis, a UAE resident was treated as entitled to protection under the agreement.</description>
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