Other Income

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....le to the income which may be taxed in Switzerland. (b) Where a resident of Switzerland derives gains from the alienation of shares which may be taxed in India according to Article 13, paragraph 5, sub-paragraph (b), India shall allow as a deduction from tax on that income, an amount equal to the income-tax paid in Switzerland on these capital gains. The deduction shall not, however, exceed that part of the Indian income-tax, which is imposed on these capital gains. 2. (a) Where a resident of Switzerland derives income which, in accordance with the provisions of this Agreement may be taxed in India, Switzerland shall, subject to the provisions of sub-paragraphs (b), (c), ^2[****], exempt such income from tax but may, in calculating ta....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....onfederation for the avoidance of double taxation. ^4[****] ^6[****]     ******************* NOTES:- 1.  Re-Numbered vide Notification No. 35 dated 07-02-2001 before it was read as, "21" 2.  Substituted vide Notification No. 35 dated 07-02-2001 before it was read as, "and (d)" 3.  Substituted vide Notification No. 35 dated 07-02-2001 before it was read as, "included services" 4.  Omitted vide Notification No. 35 dated 07-02-2001 before it was read as,  "(c) Notwithstanding the provisions of sub-paragraph (b), where a resident of Switzerland derives interest, royalties or fees f....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

...., sub-paragraph (a) (ii) or of fees for included services covered by Article 12, paragraph 4, sub-paragraph (b) (i); (bb) a deduction of 10 per cent of the gross amount of fees for included services covered by Article 12, paragraph 4, sub-paragraph (b) (ii); (ii) a credit from the Swiss tax on the income of that resident, as computed by reference to the relief referred to in the foregoing sub-paragraph of an amount of: A. 10 per cent of the gross amount of the interest referred to in Article 11, paragraph 2; B. 10 per cent of the gross amount of the royalties referred to in Article 12, paragraph 2, sub-paragraph (a), and of the fees for included services covered by Article 12, paragraph 4, sub-paragraph (....