Relief from Double taxation

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....lic of India and any item of capital situated within the Republic of India, which, according to this Agreement, may be taxed in the Republic of India. The Federal Republic of Germany, however, retains the right to take into account in the determination of its rate of tax the items of income and capital so exempted. In the case of dividends exemption shall apply only to such dividends as a....

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....t on : (i) dividends not dealt with in sub-paragraph (a) ; (ii) interest ; (iii) royalties and fees for technical services ; (iv) income in the meaning of paragraph 4 of Article 13 ; (v) directors fees ; (vi) income of artistes and sports persons. (c) For the purpose of credit refe....

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....lishment or company are derived exclusively or almost exclusively from active operations. In the case of items of income dealt with the Article 10 and the items of capital underlying such income the exemption shall apply even if the dividends are derived from holdings in other companies being residents of the Republic of India which carry on active operations and in which the company which last....

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....ic of Germany, whether directly or by deduction, and as a deduction from the tax on such capital of that resident an amount equal to the capital tax paid in the Federal Republic of Germany. Such deduction in either case shall not, however, exceed that part of the income-tax or capital tax (as computed before the deduction is given) which is attributable, as the case may be, to the income or the ca....