Category: International Tax – Interpretation of Treaty

ARTICLE 11 (3) INDIA USA – EXEMPTION IN SOURCE STATE FOR CERTAIN INTEREST Notwithstanding the provisions of paragraph 2 of this Article, interest arising in

ARTICLE 10(4) OF INDIA USA TREATY – PE OR FIXED BASE The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner

ARTICLE 10(2) OF INDIA USA TREATY – RIGHT OF SOURCE STATE TO TAX DIVIDEND However, such dividends may also be taxed in the Contracting State

ARTICLE – 4(2) OF THE OECD & UN MODEL– TIE BREAKER INDIVIDUAL ARTICLE – 4(2) OF THE OECD & UN MODEL– TIE BREAKER INDIVIDUAL CASE

ARTICLE – 4(3) – TIE BREAKER RULE – PERSON OTHER THAN AN INDIVIDUAL Where by reason of application of paragraph 1 a person other than

ARTICLE – 4(1) OF THE INDIA UAE TREATY For the purposes of this Agreement the term ‘resident of a Contracting State’ means: (a) …… ;