TaxTMI 
TaxTMI 
Protocol
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....lishment as such. If machinery or equipment is delivered from the head office or another permanent establishment of the enterprise (situated outside that Contracting State) or a third person (situated outside the Contracting State) in connection with those activities or independently therefrom there shall not be attributed to the profits of the building site or construction, assembly or installation project the value of such deliveries. (b) Income derived by a resident of a Contracting State from planning, project, construction or research activities as well as income from technical services exercised in that State in connection with a permanent establishment situated in the other Contracting State, shall not be attributed to that perman....
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....rticle 8, income from the operation of ships includes income derived from the use, maintenance or rental of containers (including trailers and related equipment for the transport of containers) in connection with the transport of goods or merchandise in international traffic. With reference to Article 10 3. For the purpose of taxation in the Federal Republic of Germany, the term dividends includes income derived by a sleeping partner ("stiller Gesellschafter") from his participation as such and distributions on certificates of an investment fund or investment trust. For the purpose of taxation in the Republic of India, any income of a similar kind will be treated alike. With reference to Articles 10 and 11 4. Notwithstanding the....
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....mpensatory imposition of corporation tax on such distributions in accordance with the provisions of German tax law. (c) The Federal Republic of Germany shall avoid double taxation by a tax credit as provided for in paragraph (1b) of Article 23, and not by a tax exemption under paragraph (1a) of Article 23, (aa) if in the Contracting States income is placed under differing provisions of the Agreement or attributed to different persons (other than under Article 9) and this conflict cannot be settled by procedure pursuant to Article 25 and (i) if as a result of such placement or attribution the relevant income would be subject to double taxation ; or (ii) if as a result of such placement or attribution the re....
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....) - upon request - and it would be possible to furnish information to the competent authority in the Republic of India under these provisions irrespective of this Article. (b) If personal data is exchanged under this Article, the following additional provisions shall apply subject to the domestic laws of each Contracting State : (i) The data supplying Contracting States shall be responsible for the accuracy of the data they supply. If it emerges that inaccurate data or data which should not have been supplied have been communicated, the receiving State shall be notified of this without delay. That State shall be obliged to correct or destroy said data; (ii) The Contracting States shall be obliged to keep official r....