https://www.taxtmi.com/acts?id=51347 The Convention applies to persons who are residents of one or both Contracting States, preserves domestic-law and other-agreement benefits, directs that disputes over whether a taxation measure falls within the Convention be resolved through the Mutual Agreement Procedure, treats income through fiscally transparent entities as income of the resident to the extent taxed as such, limits relief where tax is based on remitted amounts, and conditions treaty benefits to prevent treaty-shopping and low-tax structures while allowing competent-authority exceptions. en-us Wed, 21 May 2025 15:20:58 +0530 Wed, 21 May 2025 15:20:58 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=51347 The Convention applies to persons who are residents of one or both Contracting States, preserves domestic-law and other-agreement benefits, directs that disputes over whether a taxation measure falls within the Convention be resolved through the Mutual Agreement Procedure, treats income through fiscally transparent entities as income of the resident to the extent taxed as such, limits relief where tax is based on remitted amounts, and conditions treaty benefits to prevent treaty-shopping and low-tax structures while allowing competent-authority exceptions. Act-Rules DTAA Wed, 21 May 2025 15:20:58 +0530 https://www.taxtmi.com/acts?id=51347