https://www.taxtmi.com/notifications?id=143018 Convention allocates taxing rights between India and Japan to avoid double taxation and fiscal evasion, applying to residents and specified taxes; it defines residence and a broad concept of permanent establishment with time and activity thresholds, prescribes attribution of profits to permanent establishments on an arm's-length basis, sets source-state ceilings for dividends, interest and royalties where recipient is beneficial owner, and provides mechanisms for relief from double taxation through credit/deduction, non-discrimination protections, a mutual agreement procedure for resolving treaty application disputes, and exchange of tax information subject to confidentiality and domestic law limits. en-us Thu, 01 Mar 1990 00:00:00 +0530 Sat, 11 Jan 2025 11:56:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/notifications?id=143018 Convention allocates taxing rights between India and Japan to avoid double taxation and fiscal evasion, applying to residents and specified taxes; it defines residence and a broad concept of permanent establishment with time and activity thresholds, prescribes attribution of profits to permanent establishments on an arm's-length basis, sets source-state ceilings for dividends, interest and royalties where recipient is beneficial owner, and provides mechanisms for relief from double taxation through credit/deduction, non-discrimination protections, a mutual agreement procedure for resolving treaty application disputes, and exchange of tax information subject to confidentiality and domestic law limits. Notifications Income Tax Thu, 01 Mar 1990 00:00:00 +0530 https://www.taxtmi.com/notifications?id=143018