Double Taxation Avoidance Agreement India Cases

Adoption by the central government of an agreement between certain associations on double taxation relief. There are currently 96 Comprehensive Agreements & 14 Limited Agreements India. All of these DTAAs are available on the website: incometaxindia.gov.in/ UN model, the focus is on source-based taxation and is generally supported by developing countries. OECD models are generally adopted by industrialized countries and focus on domicile-based taxation. I hope the above will help you update your knowledge of the double taxation treaty. I look forward to your return. Do not hesitate to contact me at the mr_manish_ca@yahoo.com for more details. Explanation 3.- With regard to the elimination of doubts, it is explained that, when a term is used in an agreement concluded in accordance with paragraph 1 and is not defined by said agreement or by law, but is assigned a meaning in the communication issued in accordance with paragraph 3 and in the communication adopted in the context of this communication, the meaning is as follows: which is attributed to this provision from the date of entry into force of this agreement. and may, by notification to the Official Journal, take the necessary measures for the application of the Agreement. The shutdown of the AAR created a feeling of insecurity and panic in the head of the investor who invested on the road to the Mauricie. The judgment gave a broad interpretation of the contracts signed by India and Mauritius to avoid the tax at 3 It will also be for investors to seek the possible aspects of the ownership and management of a tax exemption agreement under the agreement. The direct and indirect transfer of shares in assets held in India is unclear. It will also be interesting to see how the tax authorities investigate the indirect transfer of shares under the India-Mauritius agreement, given that the standard perception under the tax system was that the indirect transfer of shares under the agreement was exempt from capital gains tax and that various court declarations had done the same in different cases.

However, AAR held in that judgment that the derogation under the Treaty did not apply to `indirect transfers`. In addition, AAR has gone beyond the concept of the retention rule and has also set aside somewhere the Hon`ble Supreme Court ruling in the Vodafone case3, which overturned such controversial AAR rulings. It will be interesting to see how the treaty, the retention rule and the general anti-avoidance rules will be interpreted when Tiger Global sets out for a greater vocation. . . .