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Agreement between the Government of the Republic of India and the Government of the United Arab Emirates for the avoidance of double taxation of income derived from international air transport

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....ion of the procedures required by their respective laws, as required by article 6 of the said Agreement; Now, therefore, in exercise of the powers conferred by section 90 of the Income-tax Act, 1961 (43 of 1961), and section 24A of the Companies (Profits) Surtax Act, 1964 (7 of 1964), the Central Government hereby directs that all the provisions of the said Agreement shall be given effect to in the Union of India. ANNEXURE AGREEMENT BETWEEN THE GOVERNMENT OF THE REPUBLIC OF INDIA AND THE GOVERNMENT OF THE UNITED ARAB EMIRATES FOR THE AVOIDANCE OF DOUBLE TAXATION OF INCOME DERIVED FROM INTERNATIONAL AIR TRANSPORT The Government of the Republic of India and the Government of the United Arab Emirates, Desiring to conclude an Agreement f....

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....f The United Arab Emirates" means Gulf Air and Emirates Air lines and any other enterprises designated by the Government of the United Arab Emirates; (e) The term "international traffic" means any transport by an aircraft operated by an enterprise of a Contracting State, except when the aircraft is operated solely between places in the other Contracting State; (f) The expression "operation of aircraft" means business of carriage by air of passengers, livestock, goods or mail carried on by the owners or lessees or charterers of aircraft including the sale of tickets for such transportation on behalf of other enterprises, the incidental lease of aircraft and any other activity directly connected with such transpor....

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....gains from the alienation of spares and equipment used by the enterprise in the operation of such aircraft shall be taxable only in that State. 6. Salaries, wages and other remuneration in respect of an employment exercised aboard an aircraft operated in international traffic shall be taxable only in the Contracting State where the air transport enterprise is managed and controlled, provided that the employee concerned is not a resident in the other Contracting State in accordance with the tax laws of that other State. Article 4 RESIDUAL PROVISIONS The laws in force in either of the Contracting States will continue to govern the assessment and taxation of income in the Contracting States except where express provision to the contrary is....