OBJECTIVE
In the present era of cross-border transactions across the globe, the effect of taxation is one of the important considerations for any trade and investment decisions in other countries. Where a taxpayer is resident in one country but has a source of income situated in another country it gives rise to possible double taxation, to address the same Double Taxation Avoidance Agreements (DTAAs) are entered between countries. In this webinar, we shall understand and analyse the DTAA entered by India-UAE.
Assessments of search cases involve many technical complexities due to different sets of provisions governing them. Some important issues of recent origin are tried to be covered in this presentation.
OBJECTIVE
Import of all kinds of goods and on the export of goods on certain situations attracts customs duty. The Customs Act,1962 contains provisions which govern the levy of customs duty. In this webinar, we will be learning about the basic concepts and important definitions under the Customs Act, 1962.
Overview of Companies (Auditor’s Report) Order 2020
TO BE PUBLISHED IN THE GAZETTE OF INDIA, EXTRAORDINARY,PART II, SECTION 3, SUB-SECTION (ii)]MINISTRY OF CORPORATE AFFAIRS
CONTENTS
1) BACKGROUND OF SECTION 143 OF COMPANIES ACT 2013
2) REQUIREMENT OF CARO
3) NON APPLICABILITY OF CARO 2020 TO CERTAIN COMPANIES
3) MATTERS TO BE INCLUDED IN THE AUDITORS REPORT
4) DESCRIPTION OF EACH PARAGRAPH TO BE INCLUDED IN CARO 2020
Assessments of search cases involve many technical complexities due to different sets of provisions governing them. Some important issues of recent origin are tried to be covered in this presentation.
OBJECTIVE
Import of all kinds of goods and on the export of goods on certain situations attracts customs duty. The Customs Act,1962 contains provisions which govern the levy of customs duty. In this webinar, we will be learning about the basic concepts and important definitions under the Customs Act, 1962.
Overview of Companies (Auditor’s Report) Order 2020
TO BE PUBLISHED IN THE GAZETTE OF INDIA, EXTRAORDINARY,PART II, SECTION 3, SUB-SECTION (ii)]MINISTRY OF CORPORATE AFFAIRS
CONTENTS
1) BACKGROUND OF SECTION 143 OF COMPANIES ACT 2013
2) REQUIREMENT OF CARO
3) NON APPLICABILITY OF CARO 2020 TO CERTAIN COMPANIES
3) MATTERS TO BE INCLUDED IN THE AUDITORS REPORT
4) DESCRIPTION OF EACH PARAGRAPH TO BE INCLUDED IN CARO 2020
Key Takeaways:
- What is Single Master Form
- Registration in FIRMS Portal
- Structure of FC-GPR
- Procedures and documents required
- Reason for rejection of form
CA Varun Sethi Ind AS 20 - Accounting for Government GrantsVarun Sethi
Presentation by CA Varun Sethi: Indian Financial Reporting:
IndAS 20*: Accounting for Government Grants (GG) and disclosure for government assistance
Presentation includes comparison of Ind AS 20 issued by ICAI, (converged with IAS 20 issued by IASB), with AS 12, with IAS 20, and with ICDS (Income computation and accounting standards) on Government Grants
Sectors Impacted:
1. Corporates who enjoy Export related interest rate subvention on bank loans (Eg. Sugar/ Rice industries)
2. Non profit sector,
3. Companies enjoying government investment subsidies (Central investment subsidy scheme etc)
OBJECTIVE
With the fast growth of Indian trade across borders, the Government regulations have also become stringent in order to prevent illegal import or export of goods. It is crucial for the importers and exporters to abide by these regulations. In this webinar we will be learning about the powers of the Central Government to notify goods , the responsibilities of persons acquiring notified goods or selling specified goods and precautionary steps to be taken in order to be satisfied with the identity of the purchaser.
Lecture notes on scope of total income and residental status under income ta...Dr. Sanjay Sawant Dessai
Lecture notes prepared for the students of Income tax , based on Income tax Act of India 1961. topic covered are Residential status and scope of total income of assessee.
OBJECTIVE
Goods and Services Tax (GST) is an Indirect Tax levied in India introduced in July, 2017 which was one of the most important reforms in the Indian Economy. Timely refund mechanism is essential in tax administration, as it facilitates trade through the release of blocked funds for working capital, expansion and modernisation of existing business. In this webinar, we shall be learning the procedural aspects of refund under GST law.
B C Shetty & Co., Chartered Accountants are a dominant force when it comes to dealing with International Taxation.
Here we have a small demo of what we do in this regard.
How to file form-1 (equalization levy) on new income-tax portal?Ankitasahu60
On or before the 30th of June immediately following the financial year, the statement in Form No.1 in respect of all the specified services chargeable to the equalization levy must be given.
The equalization levy would be 6% of the amount of consideration for specified services received or receivable by a non-resident not having a permanent establishment ('PE') in India, from an Indian resident carrying on business or profession, or from a non-resident having a permanent establishment in India.
Key Takeaways:
- What is Single Master Form
- Registration in FIRMS Portal
- Structure of FC-GPR
- Procedures and documents required
- Reason for rejection of form
CA Varun Sethi Ind AS 20 - Accounting for Government GrantsVarun Sethi
Presentation by CA Varun Sethi: Indian Financial Reporting:
IndAS 20*: Accounting for Government Grants (GG) and disclosure for government assistance
Presentation includes comparison of Ind AS 20 issued by ICAI, (converged with IAS 20 issued by IASB), with AS 12, with IAS 20, and with ICDS (Income computation and accounting standards) on Government Grants
Sectors Impacted:
1. Corporates who enjoy Export related interest rate subvention on bank loans (Eg. Sugar/ Rice industries)
2. Non profit sector,
3. Companies enjoying government investment subsidies (Central investment subsidy scheme etc)
OBJECTIVE
With the fast growth of Indian trade across borders, the Government regulations have also become stringent in order to prevent illegal import or export of goods. It is crucial for the importers and exporters to abide by these regulations. In this webinar we will be learning about the powers of the Central Government to notify goods , the responsibilities of persons acquiring notified goods or selling specified goods and precautionary steps to be taken in order to be satisfied with the identity of the purchaser.
Lecture notes on scope of total income and residental status under income ta...Dr. Sanjay Sawant Dessai
Lecture notes prepared for the students of Income tax , based on Income tax Act of India 1961. topic covered are Residential status and scope of total income of assessee.
OBJECTIVE
Goods and Services Tax (GST) is an Indirect Tax levied in India introduced in July, 2017 which was one of the most important reforms in the Indian Economy. Timely refund mechanism is essential in tax administration, as it facilitates trade through the release of blocked funds for working capital, expansion and modernisation of existing business. In this webinar, we shall be learning the procedural aspects of refund under GST law.
B C Shetty & Co., Chartered Accountants are a dominant force when it comes to dealing with International Taxation.
Here we have a small demo of what we do in this regard.
How to file form-1 (equalization levy) on new income-tax portal?Ankitasahu60
On or before the 30th of June immediately following the financial year, the statement in Form No.1 in respect of all the specified services chargeable to the equalization levy must be given.
The equalization levy would be 6% of the amount of consideration for specified services received or receivable by a non-resident not having a permanent establishment ('PE') in India, from an Indian resident carrying on business or profession, or from a non-resident having a permanent establishment in India.
These amendments redefine the scope and administration of the Economic Substance regime in the UAE, subject to a retrospective effect from 1st January 2019.
Corporate tax will be levied for all businesses(extraction of natural resources is excluded) and commercial activities across all the emirates in the UAE.
Economic Substance Regulations in the UAE is a principle and law that requires a business license holder to adhere to Economic Substance Return on the gross income generated from their relevant activity. The ESR law for holding companies, along with other licensed companies, was adopted in 2019.
Permanent Establishment (PE) is a crucial concept in international taxation, determining when a foreign company becomes liable to pay taxes in a host country.This article provides an overview of Permanent Establishment in India, including its definition, its types, and the impact of setting up PE in India.
Ever since the introduction of economic substance regulations in UAE, people have been raising queries about numerous things related to it. We provide answers to you.
The Easiest way to understand International taxation , Concept of Double taxation and its avoidance agreements (DTAA) and its types . Tax implication of activities of foreign enterprise in India: Mode of entry and taxation respectively.
For the first time, Tax on Goods & Services has been introduced in Gulf Countries and out of 6 GCC States, UAE & Kingdom of Soudi Arabia has already implemented VAT on supply of Goods or Services through out the Supply Chain w.e.f. 01st Jan, 2018. In this presentation, I have tried to explain the need & basis of Implementation of VAT in UAE, Taxable Transaction, Types of Supplies, Exports, VAT on Transactions between GCC states. Will bring more about UAE VAT in my next presentation. Please share your feedback in the comments section. Thanks
come and join afterschoool and spread management education to common people so that they may become entrepreneurs. spread knowledge about business, entrepreneurship and commerce.
This material is a part of our PGPSE programe. Our programme is available for any student after class 12th / graduation. AFTERSCHO☺OL conducts PGPSE, which is available free to all online students. There are no charges. PGPSE is a very rigorous programme, designed to give a comprehensive training in social entrepreneurship / spiritual entrepreneurship. This programme is aimed at those persons, who want to ultimately set up their own business enterprises which can benefit society substantially. PGPSE is a unique programme, as it combines industry consultancy, business solutions and case studies in addition to spirituality and social concerns. You can read the details at www.afterschoool.tk or at www.afterschool.tk
Impact of taxation on cross border investment Isha Joshi
Consequent to the implemented economic liberalisation in India during the 1990s, substantial international investment activity began within the Indian capital markets and through corporate vehicles with an increasingly vibrant fervour. In fact, today, Foreign Institutional Investors (FIIs) play a crucial role in the liquidity, growth and vitality seen in Indian capital markets. Simultaneously, along with increasing FII activity, as a result of the favourable economic and political climate, India also witnessed an increasing quantum of Foreign Domestic Investment (FDI).
The regulation of these investment channels and instruments was at the front and centre of economic policy debate, a part of which revolves around taxation. There is undoubtedly a proximate and intelligible nexus between taxation and the employment of these investment tools. A taxation regime that is favourable can work in effectively attracting more international investment which in turn would enhance market liquidity, activity, and growth.1 While FIIs and FDIs may appear to be similar investment channels, for the most part, they serve entirely different objectives, and operate in substantially different manners and are subject to different regulatory regimes in terms of exchange, economic and taxation policy.
In the coming sections of this paper, the authors have attempted to analyse several aspects of FII and FDI taxation in India. The first section delineates the differences in FIIs and FDIs, their market strategy, modus operandi, and objectives, while ascertaining what exactly these investment channels imply and the various investment vehicles that may be employed by foreign actors.
The subsequent section of the paper outlines the tax regime applicable to such FDIs and FIIs, depending on the organisational scheme and objective of the business vehicle so employed for the investment.
Given that FIIs and FDIs essentially involve a foreign element, the question of double taxation is one which necessarily requires to be addressed. To that end, in the third section of this paper, the authors have looked at Double Taxation Avoidance Agreements (DTAAs) (Tax Treaties) in the context of FIIs and FDIs.
SCRAPPING OF RETRO TAX PROVISIONS : A REVIVAL OF OVERSEAS INTEREST IN INDIADVSResearchFoundatio
Key Takeaways:
- Scrapping of Restrospective effect of Taxation
- Indirect transfer of assets not taxable before 28th May 2012
- Vodafone case analysis
- Draft notification to implement the amendment
Key Takeaways: - Analysis of section 45(4), section 9B of the Income Tax Act...DVSResearchFoundatio
Key Takeaways:
- Analysis of section 45(4), section 9B of the Income Tax Act and Rule 8AA and Rule 8AB of Income Tax Rules
- Illustrations to understand the relevant impact
- Critical Issues concerned with the provisions
Key Takeaways:
- Facts of the case
- Issues and Orders of the case
- Contention of the parties
- Observations by Honourable Supreme Court
- Conclusions
Key Takeaways:
- Facts of the case
- Issues and Orders of the case
- Contention of the parties
- Observations by Honourable Supreme Court
- Conclusions
FALLACIOUS DISREGARDING OF TRANSACTIONS THAT RESULT IN A TAX BENEFIT TO THE A...DVSResearchFoundatio
Key Takeaways:
- Facts of the case
- AO's contention
- Ruling of CIT(A) and issues for consideration of the ITAT
- Observations of ITAT
- Final Ruling
- Way Forward
ALLOWABILITY OF OUTSTANDING INTEREST CONVERTED INTO DEBENTURES AS AN EXPENSE ...DVSResearchFoundatio
Key Takeaways:
- Facts and issues of the case
- Rationale behind the section
- Ruling of lower jurisdiction authorities
- Rival submissions before the Honourable Supreme Court
- Observations and final rulings of Honourable Supreme Court
- Way Forward
Key Takeaways:
- Facts of the case
- Issues and Orders
- Contention of the parties
- Observations of Honourable Supreme Court
- Conclusion and way forward
Key Takeaways:
- Background and Overview of Legal Provision
- Facts of the Case
- Contentions of the Assessee and Revenue
- Supreme Court’s Verdict
- Key Learnings and Way Forward
Key Takeaways:
- Background and Overview of Legal Provision
- Facts of the Case
- Contentions of the Assessee and Revenue
- Supreme Court’s Verdict
- Key Learnings and Way Forward
AUTOMATIC VACATION OF STAY GRANTED BY TRIBUNALDCIT v. PEPSI FOODS LTD. [2021]...DVSResearchFoundatio
Key Takeaways:
- Background and Overview of Legal Provision
- Facts of the Case
- Contentions of the Assessee and Revenue
- Supreme Court’s Verdict
- Key Learnings and Way Forward
Putting the SPARK into Virtual Training.pptxCynthia Clay
This 60-minute webinar, sponsored by Adobe, was delivered for the Training Mag Network. It explored the five elements of SPARK: Storytelling, Purpose, Action, Relationships, and Kudos. Knowing how to tell a well-structured story is key to building long-term memory. Stating a clear purpose that doesn't take away from the discovery learning process is critical. Ensuring that people move from theory to practical application is imperative. Creating strong social learning is the key to commitment and engagement. Validating and affirming participants' comments is the way to create a positive learning environment.
What is the TDS Return Filing Due Date for FY 2024-25.pdfseoforlegalpillers
It is crucial for the taxpayers to understand about the TDS Return Filing Due Date, so that they can fulfill your TDS obligations efficiently. Taxpayers can avoid penalties by sticking to the deadlines and by accurate filing of TDS. Timely filing of TDS will make sure about the availability of tax credits. You can also seek the professional guidance of experts like Legal Pillers for timely filing of the TDS Return.
Enterprise Excellence is Inclusive Excellence.pdfKaiNexus
Enterprise excellence and inclusive excellence are closely linked, and real-world challenges have shown that both are essential to the success of any organization. To achieve enterprise excellence, organizations must focus on improving their operations and processes while creating an inclusive environment that engages everyone. In this interactive session, the facilitator will highlight commonly established business practices and how they limit our ability to engage everyone every day. More importantly, though, participants will likely gain increased awareness of what we can do differently to maximize enterprise excellence through deliberate inclusion.
What is Enterprise Excellence?
Enterprise Excellence is a holistic approach that's aimed at achieving world-class performance across all aspects of the organization.
What might I learn?
A way to engage all in creating Inclusive Excellence. Lessons from the US military and their parallels to the story of Harry Potter. How belt systems and CI teams can destroy inclusive practices. How leadership language invites people to the party. There are three things leaders can do to engage everyone every day: maximizing psychological safety to create environments where folks learn, contribute, and challenge the status quo.
Who might benefit? Anyone and everyone leading folks from the shop floor to top floor.
Dr. William Harvey is a seasoned Operations Leader with extensive experience in chemical processing, manufacturing, and operations management. At Michelman, he currently oversees multiple sites, leading teams in strategic planning and coaching/practicing continuous improvement. William is set to start his eighth year of teaching at the University of Cincinnati where he teaches marketing, finance, and management. William holds various certifications in change management, quality, leadership, operational excellence, team building, and DiSC, among others.
Cracking the Workplace Discipline Code Main.pptxWorkforce Group
Cultivating and maintaining discipline within teams is a critical differentiator for successful organisations.
Forward-thinking leaders and business managers understand the impact that discipline has on organisational success. A disciplined workforce operates with clarity, focus, and a shared understanding of expectations, ultimately driving better results, optimising productivity, and facilitating seamless collaboration.
Although discipline is not a one-size-fits-all approach, it can help create a work environment that encourages personal growth and accountability rather than solely relying on punitive measures.
In this deck, you will learn the significance of workplace discipline for organisational success. You’ll also learn
• Four (4) workplace discipline methods you should consider
• The best and most practical approach to implementing workplace discipline.
• Three (3) key tips to maintain a disciplined workplace.
Improving profitability for small businessBen Wann
In this comprehensive presentation, we will explore strategies and practical tips for enhancing profitability in small businesses. Tailored to meet the unique challenges faced by small enterprises, this session covers various aspects that directly impact the bottom line. Attendees will learn how to optimize operational efficiency, manage expenses, and increase revenue through innovative marketing and customer engagement techniques.
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Memorandum Of Association Constitution of Company.pptseri bangash
www.seribangash.com
A Memorandum of Association (MOA) is a legal document that outlines the fundamental principles and objectives upon which a company operates. It serves as the company's charter or constitution and defines the scope of its activities. Here's a detailed note on the MOA:
Contents of Memorandum of Association:
Name Clause: This clause states the name of the company, which should end with words like "Limited" or "Ltd." for a public limited company and "Private Limited" or "Pvt. Ltd." for a private limited company.
https://seribangash.com/article-of-association-is-legal-doc-of-company/
Registered Office Clause: It specifies the location where the company's registered office is situated. This office is where all official communications and notices are sent.
Objective Clause: This clause delineates the main objectives for which the company is formed. It's important to define these objectives clearly, as the company cannot undertake activities beyond those mentioned in this clause.
www.seribangash.com
Liability Clause: It outlines the extent of liability of the company's members. In the case of companies limited by shares, the liability of members is limited to the amount unpaid on their shares. For companies limited by guarantee, members' liability is limited to the amount they undertake to contribute if the company is wound up.
https://seribangash.com/promotors-is-person-conceived-formation-company/
Capital Clause: This clause specifies the authorized capital of the company, i.e., the maximum amount of share capital the company is authorized to issue. It also mentions the division of this capital into shares and their respective nominal value.
Association Clause: It simply states that the subscribers wish to form a company and agree to become members of it, in accordance with the terms of the MOA.
Importance of Memorandum of Association:
Legal Requirement: The MOA is a legal requirement for the formation of a company. It must be filed with the Registrar of Companies during the incorporation process.
Constitutional Document: It serves as the company's constitutional document, defining its scope, powers, and limitations.
Protection of Members: It protects the interests of the company's members by clearly defining the objectives and limiting their liability.
External Communication: It provides clarity to external parties, such as investors, creditors, and regulatory authorities, regarding the company's objectives and powers.
https://seribangash.com/difference-public-and-private-company-law/
Binding Authority: The company and its members are bound by the provisions of the MOA. Any action taken beyond its scope may be considered ultra vires (beyond the powers) of the company and therefore void.
Amendment of MOA:
While the MOA lays down the company's fundamental principles, it is not entirely immutable. It can be amended, but only under specific circumstances and in compliance with legal procedures. Amendments typically require shareholder
What are the main advantages of using HR recruiter services.pdfHumanResourceDimensi1
HR recruiter services offer top talents to companies according to their specific needs. They handle all recruitment tasks from job posting to onboarding and help companies concentrate on their business growth. With their expertise and years of experience, they streamline the hiring process and save time and resources for the company.
Premium MEAN Stack Development Solutions for Modern BusinessesSynapseIndia
Stay ahead of the curve with our premium MEAN Stack Development Solutions. Our expert developers utilize MongoDB, Express.js, AngularJS, and Node.js to create modern and responsive web applications. Trust us for cutting-edge solutions that drive your business growth and success.
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Digital Transformation and IT Strategy Toolkit and TemplatesAurelien Domont, MBA
This Digital Transformation and IT Strategy Toolkit was created by ex-McKinsey, Deloitte and BCG Management Consultants, after more than 5,000 hours of work. It is considered the world's best & most comprehensive Digital Transformation and IT Strategy Toolkit. It includes all the Frameworks, Best Practices & Templates required to successfully undertake the Digital Transformation of your organization and define a robust IT Strategy.
Editable Toolkit to help you reuse our content: 700 Powerpoint slides | 35 Excel sheets | 84 minutes of Video training
This PowerPoint presentation is only a small preview of our Toolkits. For more details, visit www.domontconsulting.com
3.0 Project 2_ Developing My Brand Identity Kit.pptxtanyjahb
A personal brand exploration presentation summarizes an individual's unique qualities and goals, covering strengths, values, passions, and target audience. It helps individuals understand what makes them stand out, their desired image, and how they aim to achieve it.
3. Legends used in the Presentation
BO Beneficial Owner
DTAA Double Taxation Avoidance Agreements
PE Permanent Establishment
POEM Place of Effective Management
UAE United Arab Emirates
4. Presentation Schema
Introduction Overview
Permanent
Establishment
Income from
Immovable
property
Business
Profits
Shipping
Associated
Enterprises
Dividends Interest Royalties
Fees for
Technical
Services
Capital Gains
Independent
Personal
Services
Dependent
Personal
Services
Directors’
Fees
Artistes and
Athletes
Government
Functions
Non-
Government
Pensions and
Annuities
Students and
Apprentices
Professors,
Teachers And
Research
Scholars
Other Income Miscellaneous
6. Introduction
In the present era of cross-border transactions across the globe, the effect of taxation is one of the
important considerations for any trade and investment decisions in another countries
Where a taxpayer is resident in one country but has a source of income situated in another country
it gives rise to possible double taxation
Double Taxation Avoidance Agreements (DTAAs) lay down rules for taxation of the income by the
source country and the residence country
Such rules are laid for various categories of income such as interest, dividends, royalties, capital
gains, business income etc.
Each category is dealt with by a separate article in the relevant DTAA
The provisions of DTAA are then compared with domestic law; whichever are beneficial can be opted by
the assessee
In this webinar, we shall focus on analysing the provisions of DTAA between India and UAE whereby a non-
resident Indian (resident of UAE) has income connected with sources in India. Thus, in this context,
Contracting State shall be UAE and other Contracting State shall be India
7. Overview of United Arab Emirates
(UAE)
The economy of the UAE is the second largest in the Middle East
The UAE enjoys a strategic location between Asia, Europe and Africa
The UAE has several multi-specialty free zones which offer several economic incentives such as exemption
from corporate taxes and import/export duties and full foreign ownership with 100 % profit repatriation
8. List of Articles
Personal Scope Shipping
Dependent Personal
Services Other Income Limitation Of Benefits
Taxes Covered Associated Enterprises Directors' Fees Capital
Diplomatic And
Consular Activities
General Definitions Dividends
Income Earned By
Entertainers And
Athletes
Income Of Government
And Institutions Entry Into Force
Resident Interest
Remuneration And
Pensions In Respect Of
Government Service
Elimination Of Double
Taxation Termination
Permanent
Establishment Royalties
Non-Government
Pensions And Annuities Non-Discrimination
Income From
Immovable Property Capital Gains
Students, Trainees And
Apprentices
Mutual Agreement
Procedure
Business Profits
Independent Personal
Services
Professors, Teachers
And Researchers
Exchange Of
Information
The list of Articles entered between India-UAE are as follows
We shall discuss the major components of income while doing the said analysis
10. Article 5 – Permanent Establishment
Permanent Establishment (PE) means a fixed place of business through which the business of the
enterprise is wholly or partly carried on
The term shall include
a place of
management ;
a branch ; an office ; a factory ; a workshop ;
a warehouse, in
relation to a person
providing storage
facilities for others
a mine, an oil or gas
well, a quarry or any
other place of
extraction of natural
resources
a firm, plantation or
other place where
agricultural, forestry,
plantation or related
activities are carried on
a building site or construction
where such site, project or
supervisory activity continues
for a period of more than 9
months
The term shall not include
he use of facilities solely for the purpose of storage or display of merchandise belonging to the enterprise ;
the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of
storage or display ;
the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of
processing by another enterprise
11. Income from Immovable property and
Business Profits
Income from immovable property may be taxed in India in which such property is situated
Immovable property shall be construed as defined by Indian laws in which the property is situated
Income tax rate for Income from Immovable property (being rental income) in India would be based on
slab rates
The profits of an enterprise of UAE shall be taxable only in UAE unless the enterprise carries on business in India
through a PE
The profits of the enterprise may be taxed in India to the extent attributable to that PE
Deduction of expenses including executive and general administrative expenses are allowed
The profits to be attributed to the PE shall be determined by the same method every year unless there is sufficient
reason to change
Income tax rate for Business Profits in India would range from 22% to 30%
Article 7 – Business Profits
Article 6 - Income from Immovable property
12. Article 8 - Shipping
Profits derived by an enterprise of UAE from the operation by that enterprise of ships in international
traffic shall be taxable only in UAE
Profits from the operation of ships in international traffic shall mean profits derived from the
transportation by sea of passengers, mail, livestock or goods and shall include
• the charter or rental of ships
• the rental of containers and related equipments used in connection with the operation of ships in
international traffic
• the gains derived from the alienation of ships, containers and related equipments owned and
operated by the enterprise in international traffic
The provisions are also applicable to profits from the participation in a pool, a joint business or an
international operating agency
Article 11 (Interest) shall not apply for interest on funds connected with the operation of ships or
aircraft in international traffic is received
Income tax rate in India for such activity is 7.5%
Operation of ships or aircraft shall mean business of transportation of persons, mail, livestock or goods, carried on by the owners or
lessees or charterers of the ships or aircraft, including the sale of tickets for transportation on behalf of others, the incidental lease of
ships or aircraft and any other activity directly connected with transportation
13. Article 9 – Associated Enterprises
Where an enterprise of UAE participates, directly or indirectly, in the management, control or capital of an
enterprise of India, or the same persons participate, directly or indirectly, in the management, control or
capital of an enterprise of UAE and an enterprise of India, profit of first mentioned enterprise may be
included in the profits of the second mentioned enterprise and taxed accordingly
14. Article 10 - Dividends
Dividends paid by a company which is a resident of UAE to a resident of India may be taxed in India
However, such dividends may also be taxed in UAE where the company paying the dividends is a resident
if the recipient is the Beneficial Owner (BO) of the dividends; such dividend shall be charged at rate not
exceeding 10 %
The provisions shall not apply if the BO, being a resident of UAE, carries on business in India where the
company paying the dividends is a resident, through a PE (as dealt specifically in Article 5 and 7)
15. Article 11 - Interest
Interest arising in UAE and paid to a resident of India may be taxed in India
However, such interest may be taxed in UAE in which it arises, but if the recipient is the BO of the interest,
the tax so charged shall not exceed
• 5 % of the gross amount of the interest if such interest is paid on a loan granted by a bank or by a
similar financial institution ; and
• Other cases - 12.5 %
Interest arising in UAE shall be exempt from tax in India provided it is derived and beneficially owned by :
• the Government, a political sub-division or a local authority of India ; or
• the Central Bank of the India
The provisions shall not apply if the BO of the interest, being a resident of UAE, carries on business in India
in which the interest arises, through a PE (as dealt specifically in Article 5 and 7)
16. Article 12 - Royalties
Royalties arising in UAE and paid to a resident of India may be taxed in India
Such royalties may also be taxed in UAE in which they arise, and according to the law of UAE, but the
tax so charged shall not exceed 10 % of the gross amount of the royalties
The provisions shall not apply if the recipient of the royalties, being a resident of UAE carries on
business in India in which the royalties arise, through a PE (as dealt specifically in Article 5 and 7)
Royalties are taxed at the rate of 10% in India
Fees for technical services is not specifically covered in DTAA between India and UAE
17. Article 13 – Capital Gains
Gains from the alienation of immovable property, may be taxed in UAE in which such property is
situated
Gains from the alienation of movable property forming part of the business property of a PE
which an enterprise of UAE has in India may be taxed in India
Gains from the alienation of shares of the capital stock of a company the property of which
consists directly or indirectly principally of immovable property situated in UAE may be taxed
in UAE. However, in other cases where gains arising from alienation of shares in UAE/ India
where the company is a resident
In all other cases gains from the alienation of any property shall be taxable only in UAE of which
the alienator is a resident
In India Capital Gains are taxable at the rate of 10%, 20% or slab rates depending on the type of
capital assets
Alienation means the sale, exchange, transfer, or relinquishment of the property or the extinguishment of any rights therein or the
compulsory acquisition thereof under any law in force in the respective Contracting States.
18. Article 14 – Independent Personal
Services
Income derived by a resident of UAE in respect of professional services or other independent activities
of a similar character shall be taxable only in UAE
However, in the following circumstances such income may also be taxed in India:
• if he has a fixed base regularly available to him in India for the purpose of performing his activities
• if his stay in India is for a period or periods amounting to or exceeding in the aggregate 183 days in
the relevant previous year
Here, the income shall be taxable to the extent attributable to the fixed base or based on his stay
The term "professional services" includes independent scientific, literary, artistic, educational or teaching activities as well as the
independent activities of physicians, surgeons, lawyers, engineers, architects, dentists and accountants.
19. Article 15 – Dependent Personal
Services
Salaries, wages and other similar remuneration derived by a resident of UAE in respect of an
employment shall be taxable in UAE unless the employment is exercised in India
Remuneration derived by a resident of UAE in respect of an employment exercised in India shall be
taxable only in the first mentioned State, if
• the recipient is present in India for a period or periods not exceeding in the aggregate 183 days in
the relevant previous year and
• the remuneration is paid by, or on behalf of, an employer who is not a resident of India, and
• the remuneration is not borne by a PE or a fixed base which the employer has in India
Remuneration in respect of an employment exercised aboard a ship or aircraft in international traffic,
may be taxed only in UAE in which the POEM of the enterprise is situated
20. Directors’ Fees, Artistes and Athletes
Directors' fees and other similar payments derived by a resident of UAE in his capacity as a
member of the board of directors of a company which is a resident of India may be taxed in India
Article 16 – Directors’ Fees
• Income derived by public entertainers such as theatre, motion picture, radio or television artistes and
musicians, and by athletes, from their personal activities as such may be taxed in UAE in which these
activities are exercised
• Where income is derived from personal activities exercised by an entertainer or an athlete in his capacity
as such, and accrues not to the entertainer or athlete himself but to another person, that income may,
be taxed in UAE/ India in which the activities of the entertainer or athlete are exercised
Article 17 - Artistes and Athletes
21. Government Functions, Non-Government
Pensions and Annuities
Remuneration, other than a pension, paid by UAE or a political sub-division or a local authority thereof to an
individual in respect of services rendered to UAE or sub-division or authority shall be taxable only in UAE
However, such remuneration shall be taxable only in India if the services are rendered in India and the individual is
a resident of India who
• is a national of India or
• did not become a resident of India solely for the purpose of rendering the services
Any pension paid by, or out of funds created by UAE or a political sub-division or a local authority thereof to an
individual in respect of services rendered to UAE or sub-division or authority shall be taxable only in UAE
However, such pension shall be taxable only in India if the individual is a resident of, and a national of India
Any pension, other than a pension referred to in article 18, or any annuity derived by a resident of UAE from
sources within India shall be taxed only in UAE
Article 18 – Government Functions
Article 19 – Non-Government Pensions and Annuities
22. Article 20 - Students and Apprentices
An individual who is resident of UAE and is temporarily present in India solely as a student at a recognised university,
college, school or other educational institution in India or as a business or technical apprentice therein, for a period not
exceeding 6 years from the date of his first arrival in India in connection with that visit, shall be exempt from tax in India
on
all remittances from UAE for the purposes of his maintenance, education or training ; and
any remuneration (not exceeding INR 20,000 or its equivalent sum in UAE currency p.a)
for personal services rendered in India with a view to supplementing the resources
available to him for such purposes
An individual who is resident of UAE and is temporarily present in India for the purpose of study, research or training
solely as a recipient of a grant, allowance or award for a period not exceeding 3 years from the date of his first arrival to
India in connection with that visit shall be exempt from tax in India on
the amount of such grant, allowance or award ;
all remittances from the UAE for the purposes of his maintenance, education or training ; and
any remuneration (not exceeding INR 20,000 or its equivalent sum in UAE currency per annum) in respect of
services in India if the services are performed in connection with his study, research, training or are incidental
thereto
23. Contd.
An individual who is resident of UAE and is temporarily present India solely as an employee of or under contract
for a period not exceeding 12 months from the date of his first arrival in India in connection with that visit shall
be exempt from tax in India on
all remittances from UAE for the purposes of his maintenance, education or training and
any remuneration, so far as it is not in excess of INR 20,000 or its equivalent sum in UAE currency
p.a, for personal services rendered in India, provided such services are in connection with the
acquisition of such experience
24. Article 21 - Professors, Teachers And
Research Scholars
• A professor, teacher and research scholar who is or was a resident of UAE immediately
before visiting India at the invitation of India or of a university, college, school or other
approved institution in India for the purpose of teaching or engaging in research, or both,
shall be exempt from tax in India on any remuneration for such teaching or research for a
period not exceeding 2 years from the date of his arrival in India
• However, it will not apply to income from research if the research is undertaken
primarily for the private benefit of a specific person or persons
25. Article 22 – Other Income
Items of income of a resident of UAE, wherever arising, which are not expressly dealt with in the
foregoing articles of this Convention, shall be taxable only in that Contracting State
The provisions shall not apply to income, other than income from immovable property if the
recipient of such income, being a resident of UAE, carries on business in India through a PE
Fees for technical services may get covered within the ambit of this Article
27. Article 23 - Capital
Capital represented by immovable property, owned by a resident of UAE and situated in India, may be
taxed in India
Capital represented by movable property forming part of the business property of a PE which an
enterprise of UAE has in India, or by movable property pertaining to a fixed base available to a resident of
UAE in India for the purpose of performing independent personal services, may be taxed in India
Capital represented by ships operated in international traffic and by movable property pertaining to the
operation of such ships, shall be taxable only in UAE in which the POEM of the enterprise is situated
28. Article 24 and 25
The Government of UAE shall be exempt from tax, including capital gains tax, in India in respect of any income
derived by UAE Government from India
Article 25 – Elimination of Double Taxation
Where a resident of India derives income or owns capital which, in accordance with the provisions of this
Agreement, may be taxed in UAE, India shall allow as a deduction from the tax on the income of that
resident an amount equal to the income-tax paid in UAE whether directly or by deduction; and as a
deduction from the tax on the capital of that resident an amount equal to the capital tax paid in UAE
Where a resident of the UAE derives income which in accordance with the provisions of this Agreement
may be taxed in India, the UAE shall allow as a deduction from the tax on income of that person an
amount equal to the tax on income paid in India
However, the credit shall not be allowed in one country for excess tax paid in another country. For e.g. If
for an income, tax levied in India is Rs. 100 and the tax levied on the same income in UAE is Rs. 80. The
UAE resident can take credit only to an extent of Rs. 80. He cannot ask refund of Rs. 20 paid in India from
the UAE government
Article 24 – Income of Government and Institutions
29. Article 27, 29 and 30
When a resident of UAE feels that action of one or both of UAE/ India will result in taxation not in accordance
with DTAA, he may present his case to the competent authorities in UAE within 2 years from the date of such
action
Article 29 – Limitation of Benefits
An entity which is a resident of UAE shall not be entitled to the benefits of this Agreement if the main
purpose or one of the main purposes of the creation of such entity was to obtain the benefits of this
Agreement that would not be otherwise available
Article 30 – Diplomatic and Consular Activities
Nothing in this Agreement shall affect the fiscal privileges of diplomatic or consular officials under the
general rules of international law or under the provisions of special agreements
Article 27 – Mutual Agreement Procedure