Double Taxation Avoidance Agreement – Article 24 Non Discrimination Article/Para No. OECD Model Tax Convention on Income and on Capital 2017 UN Model Convention 2017 24 Non Discrimination Non Discrimination In order to provide equality in terms of tax treatment, this Article provides that the tax provision cannot be discriminatory merely because one person is … Read more
Double Taxation Avoidance Agreement – Article 14 Independent Personal Services UN Model 1. Income derived by a resident of a Contracting State in respect of professional services or other activities of an independent character shall be taxable only in that State except in the following circumstances, when such income may also be taxed in the … Read more
Double Taxation Avoidance Agreement – Article 11 Taxation of Interest This Article provides the right to both the countries in respect of taxation of interest. Generally, the interest is taxed in the sourced country at a given rate on gross basis. Thereafter such income may be taxable in the country of residence with credit for … Read more
Double Taxation Avoidance Agreement – Article 7 Business Profits Article 7 of the UN Model Convention and the OECD Model Convention deals with the taxation of business profits in a cross-border context. Double Taxation Avoidance Agreement – Article 7 Business Profits Article 7(1) of the OECD Model Convention is similar to the UN Model Convention … Read more
Double Taxation Avoidance Agreement – Article 3 – General Definitions This Article provides the meaning of various terms used in the tax Treaty. If a particular term is not defined in a tax Treaty, Article 3 may provide that the meaning of such term should be construed as per the domestic tax laws. Article/Para No. … Read more
Double Taxation Avoidance Agreement – Article 1 – Persons Covered Further, Article 1(2) deals with cases of taxation of fiscally transparent entities. Article 1(3) provides that except in certain cases, the Treaty shall not restrict right of a Contracting State to tax its resident under its domestic laws. Introduction and Basic Concepts of Tax Treaty … Read more
What is Double Taxation Avoidance Agreement (DTAA) ? A DTAA, also known as double taxation avoidance agreement, is an agreement entered into between two countries, to ensure that the same income does not suffer, double taxation in the countries, who entered into such an agreement. A DTAA it’s sometimes also referred to as Tax Treaty … Read more
Elimination of Double Taxation – Article 23 – Double Taxation Avoidance Agreement Applicability of Article 23 – Elimination of Double taxation In many cases, the application of tax Treaty may result into double taxation for tax payers. In such a case, in order to provide relief to such Tax payers, Article 23 provides for the … Read more
Directors Fees – Article 16 – OECD Model tax Convention Taxation of Director’s Fees – Article 16 Article 16 – India USA Treaty Directors’ fees and similar payments derived by a resident of a Contracting State in his capacity as a member of the Board of Directors of a company which is a resident of … Read more
Article 28 – Member of Diplomatic Mission and Consular Posts ARTICLE 29– INDIA USA TREATY Nothing in this Convention shall affect the fiscal privileges of diplomatic agents or consular offices under the general rules of international law or under the provisions of special agreements. CHARACTERISTICS Not related to tax matters Provides protection to fiscal privileges … Read more