EXTRINSIC AIDS TO INTERPRETATION OF A TAX TREATY There are several extrinsic material used in interpretation of tax treaties including the following : – Interpretative
There are two views on the Interpretation of Tax Treaties. Different countries may follow either of these rules for interpretation of tax treaties. The classification
DOUBLE TAXATION AVOIDANCE AGREEMENT or DTAA MEANING DTAA Meaning – Tax treaties , which are also called Double Tax Avoidance Agreements, or DTAAs, are agreements
Treaty Definition – Article 2 of Vienna Convention on Law of Treaties, 1969 defines “Treaty” as – “Treaty” means an international agreement concluded between States
Double Taxation and Connecting Factors Taxability of a foreign entity /taxpayer, in any country depends upon the : – a) Residence of Taxpayer – Generally,
What is International Tax Law? International tax law are the tax laws, which apply to tax income from activities, that takes place in two or more
MEASURES FOR ANTI – TREATY SHOPPING IN TAX TREATIES BENEFICIAL OWNERSHIP The concept of “beneficial owner” implies, that the concessional withholding tax benefit, under a
BEPS ACTION PLANS OECD BEPS Action Plan has sets forth 15 Action Plans, which are designed to address BEPS, by bringing fundamental changes to the
WITHHOLDING TAX FROM PAYMENTS TO NON-RESIDENTS SALARY PAYABLE IN FOREIGN CURRENCY – SECTION 192 In terms of Rule 26 read with Rule 115, where tax
Income deemed to accrue or arise in India – Section 9 of Income Tax Act ACTIVITIES CONFINED TO DISPLAY OF ROUGH DIAMONDS IN SNZS [EXPLANATION
FEES FOR TECHNICAL SERVICES – SECTION 9(1)(vii) OF INCOME TAX ACT – SUMMARY OF KEY PROVISIONS AND TAXABILITY FTS payable to the non- resident ,
DEEMED ACCRUAL/ARISING OF ROYALTY INCOME – SECTION 9(1)(vi) OF INCOME TAX ACT Royalty payable to the non- resident , could be from the following payors