This document summarizes the key points of the Double Taxation Agreement between India and Bangladesh signed on May 27, 1992. It aims to avoid double taxation and prevent fiscal evasion with respect to taxes on income for the two countries. The agreement applies to individuals and companies that are residents of India or Bangladesh. It specifies the taxes covered in each country and defines terms like "resident", "permanent establishment", and assigns authority to the respective revenue boards of each country.
This document is a treaty between the United States and Bangladesh concerning investment protection and encouragement. It aims to promote economic cooperation by establishing rules for investments made by nationals and companies of one country in the territory of the other. Key provisions include: (1) requiring each country to provide fair and equitable treatment of investments from the other; (2) establishing rules for compensation in cases of expropriation of investments; (3) allowing for the free transfer of funds associated with investments; and (4) creating mechanisms for consultation and dispute settlement related to investments covered by the treaty.
This document is a double taxation agreement between the UK and Bangladesh signed in 1979. Some key points:
- It aims to avoid double taxation and prevent fiscal evasion on taxes on income and capital gains.
- It covers UK taxes like income tax, corporation tax, and capital gains tax, and Bangladesh taxes like income tax and super tax.
- It defines terms like "resident of a Contracting State" and "permanent establishment" and outlines how income from different sources like business profits, dividends, interest, and royalties will be taxed.
- It includes provisions for eliminating double taxation and procedures for resolving disputes between the two countries.
The document discusses regulations around insider trading and price sensitive information in Bangladesh. It defines price sensitive information and insider trading, and prohibits the latter. The Securities and Exchange Commission is responsible for regulating the capital market and protecting investors. It can investigate companies, inspect records, audit intermediaries, and prohibit fraudulent practices. The document also discusses prospectuses, listing and delisting of companies, restrictions on securities dealings, and information that must be included in directors' reports. Insider trading is prohibited, and insiders are defined as those who possess non-public material information.
Singapore India DTA Incorporating Protocol 2005Maverick Tan
This document summarizes an agreement between the governments of Singapore and India to avoid double taxation and prevent tax evasion with respect to income taxes. It was signed on January 24, 1994 and took effect on January 1, 1994 for Singapore and April 1, 1994 for India. The agreement defines key terms and outlines how residence and permanent establishments are determined for tax purposes. It also describes the taxes covered under the agreement.
The document discusses various laws related to real estate transactions in India, including:
1. The Indian Contract Act of 1872, which governs contract law.
2. The Transfer of Property Act of 1882, which lays out principles for transferring property through sale, lease, etc.
3. The Registration Act of 1908, which deals with registering documents to prevent fraud and conserve evidence of titles.
It also briefly mentions other relevant laws like the Income Tax Act of 1961, Wealth Tax Act of 1957, laws governing urban planning, and those administered by the Ministry of Urban Development.
This document is an agreement between Indonesia and Singapore to avoid double taxation and prevent tax evasion on income taxes. It outlines the personal and tax coverage of the agreement. Key provisions include:
- Applying to individuals and companies resident in either country.
- Covering income taxes imposed in each country, including taxes on gains, wages, and elements of income.
- Defining the existing taxes covered in each country.
- Allowing amendments if tax laws change significantly in either country.
The document outlines draft provisions for an agreement on trade in services, investment, and e-commerce between the EU and US. It includes 7 chapters covering general provisions, investment, cross-border supply of services, temporary entry of natural persons, regulatory framework, electronic commerce, and exceptions. The key points are:
1. It seeks to progressively liberalize trade in services, investment, and e-commerce cooperation between the EU and US while maintaining the ability to regulate in the public interest.
2. It defines terms like natural/juridical persons, investments, cross-border supply of services, and establishes scope and coverage rules.
3. It includes provisions on market access and national treatment for investments
This agreement establishes a framework for avoiding double taxation and preventing tax evasion between Indonesia and South Korea with respect to income taxes. It covers the taxes imposed by each country that are subject to this agreement. It defines terms like "resident", "permanent establishment", and outlines rules for determining residency for individuals and companies for tax purposes. The agreement also specifies what level of business activity or property ownership in one country creates a taxable presence that may be taxed by that country.
This document is a treaty between the United States and Bangladesh concerning investment protection and encouragement. It aims to promote economic cooperation by establishing rules for investments made by nationals and companies of one country in the territory of the other. Key provisions include: (1) requiring each country to provide fair and equitable treatment of investments from the other; (2) establishing rules for compensation in cases of expropriation of investments; (3) allowing for the free transfer of funds associated with investments; and (4) creating mechanisms for consultation and dispute settlement related to investments covered by the treaty.
This document is a double taxation agreement between the UK and Bangladesh signed in 1979. Some key points:
- It aims to avoid double taxation and prevent fiscal evasion on taxes on income and capital gains.
- It covers UK taxes like income tax, corporation tax, and capital gains tax, and Bangladesh taxes like income tax and super tax.
- It defines terms like "resident of a Contracting State" and "permanent establishment" and outlines how income from different sources like business profits, dividends, interest, and royalties will be taxed.
- It includes provisions for eliminating double taxation and procedures for resolving disputes between the two countries.
The document discusses regulations around insider trading and price sensitive information in Bangladesh. It defines price sensitive information and insider trading, and prohibits the latter. The Securities and Exchange Commission is responsible for regulating the capital market and protecting investors. It can investigate companies, inspect records, audit intermediaries, and prohibit fraudulent practices. The document also discusses prospectuses, listing and delisting of companies, restrictions on securities dealings, and information that must be included in directors' reports. Insider trading is prohibited, and insiders are defined as those who possess non-public material information.
Singapore India DTA Incorporating Protocol 2005Maverick Tan
This document summarizes an agreement between the governments of Singapore and India to avoid double taxation and prevent tax evasion with respect to income taxes. It was signed on January 24, 1994 and took effect on January 1, 1994 for Singapore and April 1, 1994 for India. The agreement defines key terms and outlines how residence and permanent establishments are determined for tax purposes. It also describes the taxes covered under the agreement.
The document discusses various laws related to real estate transactions in India, including:
1. The Indian Contract Act of 1872, which governs contract law.
2. The Transfer of Property Act of 1882, which lays out principles for transferring property through sale, lease, etc.
3. The Registration Act of 1908, which deals with registering documents to prevent fraud and conserve evidence of titles.
It also briefly mentions other relevant laws like the Income Tax Act of 1961, Wealth Tax Act of 1957, laws governing urban planning, and those administered by the Ministry of Urban Development.
This document is an agreement between Indonesia and Singapore to avoid double taxation and prevent tax evasion on income taxes. It outlines the personal and tax coverage of the agreement. Key provisions include:
- Applying to individuals and companies resident in either country.
- Covering income taxes imposed in each country, including taxes on gains, wages, and elements of income.
- Defining the existing taxes covered in each country.
- Allowing amendments if tax laws change significantly in either country.
The document outlines draft provisions for an agreement on trade in services, investment, and e-commerce between the EU and US. It includes 7 chapters covering general provisions, investment, cross-border supply of services, temporary entry of natural persons, regulatory framework, electronic commerce, and exceptions. The key points are:
1. It seeks to progressively liberalize trade in services, investment, and e-commerce cooperation between the EU and US while maintaining the ability to regulate in the public interest.
2. It defines terms like natural/juridical persons, investments, cross-border supply of services, and establishes scope and coverage rules.
3. It includes provisions on market access and national treatment for investments
This agreement establishes a framework for avoiding double taxation and preventing tax evasion between Indonesia and South Korea with respect to income taxes. It covers the taxes imposed by each country that are subject to this agreement. It defines terms like "resident", "permanent establishment", and outlines rules for determining residency for individuals and companies for tax purposes. The agreement also specifies what level of business activity or property ownership in one country creates a taxable presence that may be taxed by that country.
This document discusses various laws related to real estate transactions in India. It outlines 16 key acts that govern this area like the Indian Contract Act 1872, Transfer of Property Act 1882, Registration Act 1908, Urban Land Ceiling Act 1976, Land Acquisition Act 1894, and Income Tax Act 1961. These acts cover aspects like contract enforcement, property transfer rules, registration formalities, land ownership ceilings, land acquisition for government projects, and taxation. Real estate transactions must comply with the relevant provisions of these central and state laws.
The document is an amendment bill to further amend the Benami Transactions (Prohibition) Act of 1988 in India. Some key points:
- It proposes to substitute new definitions for terms like "benami property", "benami transaction", and establishes new authorities like the Adjudicating Authority and Appellate Tribunal.
- It prohibits benami transactions initiated after the date of commencement of this amendment act and introduces penal provisions.
- It also substitutes sections regarding confiscation of benami property and prohibits re-transfer of such property.
- New chapters are inserted establishing the Adjudicating Authority, its composition, powers, and terms of office of members.
The document discusses securities and listing requirements according to Indian law and stock exchange regulations. It defines securities according to the Securities Contracts Regulation Act to include shares, bonds, and other financial instruments. It then outlines the powers of the central government and Securities and Exchange Board of India regarding recognition of stock exchanges, supervision of activities, and regulation of listings. Finally, it provides details on listing requirements for companies on the Bombay Stock Exchange and National Stock Exchange of India, including eligibility criteria, ongoing compliance, and fees.
The document provides an overview of benami transactions and the Benami Transactions (Prohibition) Act 1988 in India. Some key points:
- Benami means "property without name" and refers to transactions where property is purchased in someone else's name without intending to benefit them.
- The 1988 Act was introduced to prohibit benami transactions and recover properties held benami, as such transactions were previously abused to evade taxes, circumvent land ceilings, and commit fraud.
- Under the Act, benami transactions are prohibited and no suits can be filed to claim rights over benami properties. Benami properties are also liable for acquisition by authorities. However, the Act had deficiencies in implementation and scope
The document compares amendments proposed by the Indian government to the Benami Transactions (Prohibition) Amendment Bill of 2015. Key proposed amendments include narrowing the definition of benami transactions, exempting certain property transfers where stamp duty was paid, and allowing authorized representatives during adjudication proceedings. The Standing Committee on Finance had recommended some of these amendments, including qualifications for the Appellate Tribunal Chairperson. The Committee also suggested addressing unaccounted wealth through income tax laws and digitizing land records instead of a separate benami law.
This document is the Securities Contracts (Regulation) Act of 1956 which establishes regulations for stock exchanges in India. It defines key terms related to securities and stock exchanges. It also outlines the process for a stock exchange to apply for recognition by the Central Government, including submitting details on its bye-laws, governing body, and management structure. The purpose of the Act is to regulate transactions in securities and recognize stock exchanges that meet certain criteria.
This document outlines the Financial Institutions Ordinance of 2001 in Pakistan. The ordinance aims to repeal and re-enact the Banking Companies (Recovery of Loans, Advances, Credits and Finances) Act of 1997 with some modifications. It establishes Banking Courts to handle cases related to recovery of finances extended by financial institutions in a timely manner. The ordinance defines key terms, outlines the duties of customers to fulfill obligations, and sets out procedures for financial institutions to recover written-off finances expeditiously through the new Banking Courts.
The document summarizes new rules notified in India that permit cross-border mergers through a scheme sanctioned by the National Company Law Tribunal. Key points:
- Section 234 of the Companies Act 2013 and new Rule 25A allow an Indian company to merge with a foreign company or vice versa, as long as the foreign company is from a recognized jurisdiction.
- Mergers require compliance with Sections 230-232 of the Act, RBI approval, valuation of both companies by qualified valuers, and regulations on foreign investments into India if an Indian company merges with a foreign one.
- If an Indian company merges into a foreign one, regulations on overseas investments will apply to the resultant foreign company.
This document is an agreement between the governments of the United States and Vietnam to avoid double taxation and prevent tax evasion on income. It defines key terms like "resident", "permanent establishment", and outlines which taxes are covered. It also establishes rules for attributing taxable income to permanent establishments and determining deductions. The agreement aims to provide clarity on tax obligations and ensure neither country taxes the same income twice.
The document provides information on arbitration and enforcement of foreign judgments in Kuwait. It discusses:
- International treaties Kuwait has signed related to arbitration and enforcement, including the New York Convention.
- Kuwait's arbitration system being similar to other jurisdictions, using both institutional and judicial arbitration.
- The main arbitration bodies in Kuwait operating under its civil and commercial laws.
- Foreign arbitration decisions and court decisions being recognized based on reciprocity.
- Mandatory procedures that must be followed in Kuwaiti arbitration, including requirements for arbitration agreements.
This document is Vietnam's Law on Foreign Investment, which aims to expand economic cooperation with foreign countries and modernize Vietnam's economy. It establishes the legal framework for foreign direct investment in Vietnam. Key points:
- It encourages foreign investment that respects Vietnam's independence and laws, and benefits both sides. Vietnam will protect investors' capital and legal rights.
- It defines terms like foreign investor, joint venture, business cooperation contract, capital contribution, and reinvestment.
- It allows three main forms of foreign investment: business cooperation, joint ventures, and 100% foreign-owned enterprises.
- It guarantees foreign investors will be treated fairly and their property protected from expropriation. Investors can
This presentation discusses benami transactions in light of demonetization. It begins by highlighting key points of demonetization and the Prohibition of Benami Property Transactions Act of 1988. It defines what constitutes a benami property and transaction, providing examples of cash and stock being considered benami property. Exceptions to benami transactions are outlined, along with impacts such as 100% confiscation of benami property and imprisonment. The presentation explains how benamidars (property holders) and beneficial owners (intended beneficiaries) are impacted under the new Act.
Multilateral instrument (MLI) Final provisions [Articles 27-39]DVSResearchFoundatio
The document summarizes the final provisions (Articles 27-39) of the Multilateral Instrument (MLI). It provides an overview of key aspects like signature and ratification process, reservations, notifications, entry into force, interpretation and amendments. Specifically, it outlines rules for signature, reservations, notifications by parties, subsequent modifications to covered tax agreements, conferences of parties, interpretation and implementation, amendments, entry into force, entry into effect, withdrawal and the depositary.
The benami transactions (prohibitions) amendment act (1)Himanshu Goyal
The document summarizes the Prohibition of Benami Property Transactions Act of 1988 as amended in 2016 in India. Some key points:
- The act prohibits benami transactions where one person provides consideration for a property but it is held in another person's name. Such properties are liable to be confiscated.
- The 2016 amendment strengthened penalties, setting up adjudicating authorities and an appellate tribunal to deal with benami cases.
- Transactions done for illegitimate purposes like concealing black money or evading taxes come under the purview of benami transactions according to the act.
- Properties involved in benami transactions are liable to face attachment or confiscation and individuals can be fined or imprisoned for
1) The Life Insurance Corporation Act of 1956 nationalized the life insurance business in India and established the Life Insurance Corporation of India (LIC) to take over the business and assets of existing life insurers.
2) The LIC was given powers to carry on life insurance business both in India and abroad, invest funds, borrow money, and enter into arrangements to further its business operations.
3) The act also outlined the process for transferring existing life insurance policies, employees, assets, and documents of private insurers to the LIC.
This document provides information on non-profit organizations in India, specifically trusts and societies. It discusses the key aspects of forming and registering a trust or society, including the required documents, procedures, and essential elements. Trusts can be formed by individuals or organizations and require a trustee, beneficiary, and trust property. Societies require a minimum of seven members and are registered through memorandum of association and rules/regulations. Section 25 companies are a specific type of non-profit company regulated by the Companies Act. The document compares trusts, societies, and Section 25 companies and their formation and governance processes.
Companies (Incorporation) Third Amendment Rules, 2016GAURAV KR SHARMA
The notification amends the Companies (Incorporation) Rules, 2014 to:
1. Allow a natural person to be a member of only one One Person Company.
2. Require consent from trademark owners when including their trademarks in company names.
3. Simplify document filing requirements and allow digital signatures for some documents.
4. Introduce new rules for converting unlimited liability companies to limited liability companies.
CONVENTIONBETWEENTHE ROYAL GOVERNMENT OF THAILANDANDTHE GOVERNMENT.docxmaxinesmith73660
This document outlines a convention between Thailand and Singapore to avoid double taxation and prevent tax evasion on income. It details that the governments desire to conclude an agreement (Article 1), the taxes covered which include income taxes (Article 2), definitions of terms like resident and permanent establishment (Articles 3-5), and how to tax different types of income including business profits, shipping/air transport, associated enterprises, dividends, and interest (Articles 6-11). The purpose is to establish a framework for taxing income of residents in one or both countries in order to eliminate double taxation.
This document is a convention between Moldova and Bosnia and Herzegovina to avoid double taxation and prevent tax evasion on income and property taxes. It outlines how income earned in one country by residents of the other will be taxed. It defines terms like resident, permanent establishment, and outlines which specific taxes are covered. It also provides rules for taxing business profits, international transportation income, property income, and dividends between the two countries.
This document discusses various laws related to real estate transactions in India. It outlines 16 key acts that govern this area like the Indian Contract Act 1872, Transfer of Property Act 1882, Registration Act 1908, Urban Land Ceiling Act 1976, Land Acquisition Act 1894, and Income Tax Act 1961. These acts cover aspects like contract enforcement, property transfer rules, registration formalities, land ownership ceilings, land acquisition for government projects, and taxation. Real estate transactions must comply with the relevant provisions of these central and state laws.
The document is an amendment bill to further amend the Benami Transactions (Prohibition) Act of 1988 in India. Some key points:
- It proposes to substitute new definitions for terms like "benami property", "benami transaction", and establishes new authorities like the Adjudicating Authority and Appellate Tribunal.
- It prohibits benami transactions initiated after the date of commencement of this amendment act and introduces penal provisions.
- It also substitutes sections regarding confiscation of benami property and prohibits re-transfer of such property.
- New chapters are inserted establishing the Adjudicating Authority, its composition, powers, and terms of office of members.
The document discusses securities and listing requirements according to Indian law and stock exchange regulations. It defines securities according to the Securities Contracts Regulation Act to include shares, bonds, and other financial instruments. It then outlines the powers of the central government and Securities and Exchange Board of India regarding recognition of stock exchanges, supervision of activities, and regulation of listings. Finally, it provides details on listing requirements for companies on the Bombay Stock Exchange and National Stock Exchange of India, including eligibility criteria, ongoing compliance, and fees.
The document provides an overview of benami transactions and the Benami Transactions (Prohibition) Act 1988 in India. Some key points:
- Benami means "property without name" and refers to transactions where property is purchased in someone else's name without intending to benefit them.
- The 1988 Act was introduced to prohibit benami transactions and recover properties held benami, as such transactions were previously abused to evade taxes, circumvent land ceilings, and commit fraud.
- Under the Act, benami transactions are prohibited and no suits can be filed to claim rights over benami properties. Benami properties are also liable for acquisition by authorities. However, the Act had deficiencies in implementation and scope
The document compares amendments proposed by the Indian government to the Benami Transactions (Prohibition) Amendment Bill of 2015. Key proposed amendments include narrowing the definition of benami transactions, exempting certain property transfers where stamp duty was paid, and allowing authorized representatives during adjudication proceedings. The Standing Committee on Finance had recommended some of these amendments, including qualifications for the Appellate Tribunal Chairperson. The Committee also suggested addressing unaccounted wealth through income tax laws and digitizing land records instead of a separate benami law.
This document is the Securities Contracts (Regulation) Act of 1956 which establishes regulations for stock exchanges in India. It defines key terms related to securities and stock exchanges. It also outlines the process for a stock exchange to apply for recognition by the Central Government, including submitting details on its bye-laws, governing body, and management structure. The purpose of the Act is to regulate transactions in securities and recognize stock exchanges that meet certain criteria.
This document outlines the Financial Institutions Ordinance of 2001 in Pakistan. The ordinance aims to repeal and re-enact the Banking Companies (Recovery of Loans, Advances, Credits and Finances) Act of 1997 with some modifications. It establishes Banking Courts to handle cases related to recovery of finances extended by financial institutions in a timely manner. The ordinance defines key terms, outlines the duties of customers to fulfill obligations, and sets out procedures for financial institutions to recover written-off finances expeditiously through the new Banking Courts.
The document summarizes new rules notified in India that permit cross-border mergers through a scheme sanctioned by the National Company Law Tribunal. Key points:
- Section 234 of the Companies Act 2013 and new Rule 25A allow an Indian company to merge with a foreign company or vice versa, as long as the foreign company is from a recognized jurisdiction.
- Mergers require compliance with Sections 230-232 of the Act, RBI approval, valuation of both companies by qualified valuers, and regulations on foreign investments into India if an Indian company merges with a foreign one.
- If an Indian company merges into a foreign one, regulations on overseas investments will apply to the resultant foreign company.
This document is an agreement between the governments of the United States and Vietnam to avoid double taxation and prevent tax evasion on income. It defines key terms like "resident", "permanent establishment", and outlines which taxes are covered. It also establishes rules for attributing taxable income to permanent establishments and determining deductions. The agreement aims to provide clarity on tax obligations and ensure neither country taxes the same income twice.
The document provides information on arbitration and enforcement of foreign judgments in Kuwait. It discusses:
- International treaties Kuwait has signed related to arbitration and enforcement, including the New York Convention.
- Kuwait's arbitration system being similar to other jurisdictions, using both institutional and judicial arbitration.
- The main arbitration bodies in Kuwait operating under its civil and commercial laws.
- Foreign arbitration decisions and court decisions being recognized based on reciprocity.
- Mandatory procedures that must be followed in Kuwaiti arbitration, including requirements for arbitration agreements.
This document is Vietnam's Law on Foreign Investment, which aims to expand economic cooperation with foreign countries and modernize Vietnam's economy. It establishes the legal framework for foreign direct investment in Vietnam. Key points:
- It encourages foreign investment that respects Vietnam's independence and laws, and benefits both sides. Vietnam will protect investors' capital and legal rights.
- It defines terms like foreign investor, joint venture, business cooperation contract, capital contribution, and reinvestment.
- It allows three main forms of foreign investment: business cooperation, joint ventures, and 100% foreign-owned enterprises.
- It guarantees foreign investors will be treated fairly and their property protected from expropriation. Investors can
This presentation discusses benami transactions in light of demonetization. It begins by highlighting key points of demonetization and the Prohibition of Benami Property Transactions Act of 1988. It defines what constitutes a benami property and transaction, providing examples of cash and stock being considered benami property. Exceptions to benami transactions are outlined, along with impacts such as 100% confiscation of benami property and imprisonment. The presentation explains how benamidars (property holders) and beneficial owners (intended beneficiaries) are impacted under the new Act.
Multilateral instrument (MLI) Final provisions [Articles 27-39]DVSResearchFoundatio
The document summarizes the final provisions (Articles 27-39) of the Multilateral Instrument (MLI). It provides an overview of key aspects like signature and ratification process, reservations, notifications, entry into force, interpretation and amendments. Specifically, it outlines rules for signature, reservations, notifications by parties, subsequent modifications to covered tax agreements, conferences of parties, interpretation and implementation, amendments, entry into force, entry into effect, withdrawal and the depositary.
The benami transactions (prohibitions) amendment act (1)Himanshu Goyal
The document summarizes the Prohibition of Benami Property Transactions Act of 1988 as amended in 2016 in India. Some key points:
- The act prohibits benami transactions where one person provides consideration for a property but it is held in another person's name. Such properties are liable to be confiscated.
- The 2016 amendment strengthened penalties, setting up adjudicating authorities and an appellate tribunal to deal with benami cases.
- Transactions done for illegitimate purposes like concealing black money or evading taxes come under the purview of benami transactions according to the act.
- Properties involved in benami transactions are liable to face attachment or confiscation and individuals can be fined or imprisoned for
1) The Life Insurance Corporation Act of 1956 nationalized the life insurance business in India and established the Life Insurance Corporation of India (LIC) to take over the business and assets of existing life insurers.
2) The LIC was given powers to carry on life insurance business both in India and abroad, invest funds, borrow money, and enter into arrangements to further its business operations.
3) The act also outlined the process for transferring existing life insurance policies, employees, assets, and documents of private insurers to the LIC.
This document provides information on non-profit organizations in India, specifically trusts and societies. It discusses the key aspects of forming and registering a trust or society, including the required documents, procedures, and essential elements. Trusts can be formed by individuals or organizations and require a trustee, beneficiary, and trust property. Societies require a minimum of seven members and are registered through memorandum of association and rules/regulations. Section 25 companies are a specific type of non-profit company regulated by the Companies Act. The document compares trusts, societies, and Section 25 companies and their formation and governance processes.
Companies (Incorporation) Third Amendment Rules, 2016GAURAV KR SHARMA
The notification amends the Companies (Incorporation) Rules, 2014 to:
1. Allow a natural person to be a member of only one One Person Company.
2. Require consent from trademark owners when including their trademarks in company names.
3. Simplify document filing requirements and allow digital signatures for some documents.
4. Introduce new rules for converting unlimited liability companies to limited liability companies.
CONVENTIONBETWEENTHE ROYAL GOVERNMENT OF THAILANDANDTHE GOVERNMENT.docxmaxinesmith73660
This document outlines a convention between Thailand and Singapore to avoid double taxation and prevent tax evasion on income. It details that the governments desire to conclude an agreement (Article 1), the taxes covered which include income taxes (Article 2), definitions of terms like resident and permanent establishment (Articles 3-5), and how to tax different types of income including business profits, shipping/air transport, associated enterprises, dividends, and interest (Articles 6-11). The purpose is to establish a framework for taxing income of residents in one or both countries in order to eliminate double taxation.
This document is a convention between Moldova and Bosnia and Herzegovina to avoid double taxation and prevent tax evasion on income and property taxes. It outlines how income earned in one country by residents of the other will be taxed. It defines terms like resident, permanent establishment, and outlines which specific taxes are covered. It also provides rules for taxing business profits, international transportation income, property income, and dividends between the two countries.
Double taxation avoidance agreement between india and canadarhejkrhfkBaivabiNayak
The document discusses the Double Taxation Avoidance Agreement (DTAA) between India and Canada. Some key points:
- The DTAA was signed in 1985 and came into effect in 1997 to help taxpayers avoid double taxation on the same income earned in both countries.
- It applies to taxes on income and capital imposed by India and Canada. This includes taxes on things like profits, dividends, interest, royalties.
- The DTAA defines terms like residence, permanent establishment, and outlines how different types of income like business profits, shipping/air transport income, capital gains, pensions are taxed under the agreement.
- The overall aim is to help residents of both countries avoid being tax
Double taxation occurs when the same income is taxed by both the country where it originates (source country) and the country of the taxpayer's residence (residence country). To reduce barriers to international trade, countries often negotiate double taxation avoidance agreements (DTAAs) which allocate taxing rights between the two countries. India has entered into over 60 such agreements. DTAAs aim to eliminate double taxation through methods like exemption (one country does not tax) or tax credit (residence country provides credit for taxes paid in source country). They define terms like permanent establishment that determine when business income can be taxed in the source country. DTAAs and limitations of benefits clauses help prevent treaty shopping where third parties get benefits not
Magnetic resonance imaging (MRI) is a medical imaging technique that uses a magnetic field and computer-generated radio waves to create detailed images of the organs and tissues in your body.
Most MRI machines are large, tube-shaped magnets. When you lie inside an MRI machine, the magnetic field temporarily realigns water molecules in your body. Radio waves cause these aligned atoms to produce faint signals, which are used to create cross-sectional MRI images — like slices in a loaf of bread.
The MRI machine can also produce 3D images that can be viewed from different angles.
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Why it's done
MRI is a noninvasive way for your doctor to examine your organs, tissues and skeletal system. It produces high-resolution images of the inside of the body that help diagnose a variety of problems.
MRI of the brain and spinal cord
MRI is the most frequently used imaging test of the brain and spinal cord. It's often performed to help diagnose:
Aneurysms of cerebral vessels
Disorders of the eye and inner ear
Multiple sclerosis
Spinal cord disorders
Stroke
Tumors
Brain injury from trauma
A special type of MRI is the functional MRI of the brain (fMRI). It produces images of blood flow to certain areas of the brain. It can be used to examine the brain's anatomy and determine which parts of the brain are handling critical functions.
This helps identify important language and movement control areas in the brains of people being considered for brain surgery. Functional MRI can also be used to assess damage from a head injury or from disorders such as Alzheimer's disease.
MRI of the heart and blood vessels
MRI that focuses on the heart or blood vessels can assess:
Size and function of the heart's chambers
Thickness and movement of the walls of the heart
Extent of damage caused by heart attacks or heart disease
Structural problems in the aorta, such as aneurysms or dissections
Inflammation or blockages in the blood vessels
Baker mc kenzie dec newsletter 2nd partkiranprince_c
The Indonesian government formed a HNWI Tax Office in 2009 to increase tax compliance from high net worth individuals (HNWIs) with over $1 million in assets. Currently there are 1,200 taxpayers registered in this office, all residing in Jakarta. The office monitors HNWI transactions but tax revenue has been small as most income is from salaries and dividends already taxed. The government is considering expanding the number and locations of HNWIs covered by this office.
New regulations were issued to prevent tax treaty abuse by requiring certificates of residency and determining if recipients are the beneficial owners of income. The regulations also outline situations considered misuse and consequences like normal withholding tax rates. Indonesia recently
1. To trade in the domestic market in Patna, Bihar, key documents required include registration for Central Sales Tax (CST), Bihar Value Added Tax (VAT), and a labour certificate.
2. For the CST and VAT registrations, documents like identity proof, address proof, municipality receipts, and bank statements must be submitted to the local sales tax office.
3. Quarterly tax returns also need to be filed showing goods purchased and sold, along with proof of tax paid. A road permit form is required for inter-state purchases, while an internal C form allows payment of a lower 2% CST rate versus 5% without the form.
The document discusses the due diligence requirements for cross border transactions and mergers. It covers:
- The key definitions under regulations for cross border mergers between an Indian company and foreign company.
- The allowability, vulnerability, accountability, and explainability aspects that must be considered for cross border transactions.
- The conditions under which an Indian company can merge with a foreign company or vice versa, including compliance with FEMA regulations, treatment of offices and assets/liabilities, valuation requirements, and other regulatory conditions.
- Specific provisions for inbound and outbound mergers depending on whether the resultant company is Indian or foreign. This includes timelines for compliance on guarantees, borrowings, and non-compliant assets.
This document summarizes the compulsory registration requirements under the Goods and Services Tax (GST) law in India. It outlines the aggregate turnover thresholds for requiring registration in different states and union territories. It also lists other specified cases where registration is compulsory, such as for inter-state suppliers, e-commerce operators, and persons supplying online information from outside India. The document provides definitions and explanations of key terms related to registration such as "person", "supplier", "business vertical", and "supply". It was prepared by Pradeep Goyal, a Chartered Accountant, for educational purposes to provide a general understanding of the GST registration requirements, not professional tax advice.
This document defines key concepts related to persons under tax law, including individuals, associations of persons, and companies. It provides that an individual, company, association of persons, government, or public international organization shall be treated as a person. It also defines resident and non-resident persons and provides principles for taxing individuals, associations of persons, and companies separately. Income of a company's shareholders from dividends is taxed separately from other income of the company.
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The document discusses tax residency certificates (TRC) which are required to claim benefits under double taxation avoidance agreements (DTAA). It provides information on eligibility requirements for corporations and individuals to obtain a TRC from Dubai, including having a permanent establishment, trade license, or meeting residency criteria. An example case study is given of a Poland-based company obtaining a TRC for its Dubai subsidiary to avail tax treaty benefits between Poland and Dubai by working with Intuit Consultancy to ensure compliance and submit the proper application materials.
The document outlines a proposed free trade agreement between the United States and Morocco. The agreement seeks to strengthen economic ties and promote trade liberalization between the two countries by reducing barriers and establishing clear rules. It covers various aspects of bilateral trade such as tariffs, investment, services, intellectual property, labor and environmental standards. The overall goal is to establish a free trade area that benefits both economies and contributes to regional economic integration.
The document discusses the tax treatment of income from immovable property under the OECD Model Convention.
Key points:
- Article 6 of the OECD Model Convention grants primary right to tax income from immovable property to the source state where the property is located. The residence state may also tax but must provide relief from double taxation.
- Income includes rental income, income from agriculture/forestry, and capital gains from sale of immovable property.
- The source state has primary right to tax capital gains on sale of immovable property under Article 13. Gains on movable property of a PE are also taxed in the source state.
This document provides an overview of income tax systems in India and Australia. It discusses the history and introduction of income tax in both countries, key aspects of how income tax is levied and collected, and compares some key tax rates between the two countries. It also summarizes the objectives and provisions of a tax treaty signed between India and Australia in 2011 to avoid double taxation and help facilitate economic cooperation between the two countries.
Organizations over the globe are investigating freedoms to reach out in different topographies as globalization gets urgent. The likelihood to become worldwide pioneers is the thing that is constraining an ever-increasing number of organizations out of their nations of origin. We, Lex N Tax is the best International Taxation that serves you in each circle of worldwide tax collection.
Serving in different purviews additionally delivers freedoms to diminish expenses and increment piece of the overall industry around the world. Notwithstanding, the mind boggling laws, remembering the tax assessment laws for various regions, can execute abroad extension time depleting and costly. Regardless of whether you are a homegrown Indian organization pondering to extend abroad or an unfamiliar organization trying to put resources into India, you should know the laws and guidelines that can impact your business methodologies and plans. We have global coalitions and have close binds with our unfamiliar offshoots Lex N Tax have the specialized in International Taxation Services to help you in exploring through the perplexing labyrinth of global duty laws around the world. Lex N Tax Associates one the Best Tax Consultants Services.
Vietnam LAW ON ENTERPRISES - Anphabe.Comduynguyentt
This Vietnam Enterprises Law provides for the establishment, management organization and operation of limited
liability companies, shareholding companies, partnerships and private enterprises in all economic
sectors (hereinafter referred to as enterprises); provides for corporate groups.
The whole presentation talks about the law that should be followed by companies in case of merger in both the case of merger within India and foreign company
1. The National Board of Revenue (NBR) is calling for applications from eligible candidates to participate in the VAT Officer (VO) recruitment exam-2017 in accordance with the VAT Act of 1984 and VAT Rules of 1984.
2. Candidates must have a bachelor's or master's degree in subjects like law, accounting, banking or finance from a recognized university in Bangladesh or abroad. Applications must be submitted online by March 31, 2017 along with required documents.
3. The written exam will have questions on tax laws, accounting and finance. It will carry 100 marks over 3 hours, and an oral exam carrying 50 marks will also be conducted. The exam date will be notified later via notice.
The document appears to be a scanned copy of a passport application form containing personal details such as name, date of birth, place of birth, nationality, etc. It includes sections for address, references, declaration, official use and a number of pages with the text "Scanned with CamScanner" at the bottom, indicating it was scanned from a hard copy document.
This document lists contact information for various chartered accountant firms in Bangladesh, including their addresses, contact numbers, emails, websites and names of proprietors or partners. Some firms have multiple branches located in Dhaka and Chattogram. The firms provide services like auditing, taxation, financial and management consultancy.
(1) The document discusses technical service fees charged for providing various technical services to foreign entities. It provides definitions and examples of different types of technical fees - professional service fees, technical service fees, technical know-how or technical assistance fees.
(2) Guidelines are given on calculating the rate for technical service fees, which is the number of foreign employees multiplied by a certain percentage of their salary. Registration of agreements related to technical service fees must be done according to the Registration Act.
(3) Examples are given of technical services that can be provided and the types of technical fees that can be charged for those services.
This document summarizes amendments made to several laws in Bangladesh related to banking and financial regulations. Key points:
- It amends definitions in the Bank Company Act 1991 related to terms like "banking company", "controlled entity", "family member", etc.
- It amends sections 7, 13, 14, 14K, 14L of the Bank Company Act 1991 related to custodial powers, restructured loans, limits on loan amounts to individuals/entities.
- It inserts new definitions for terms used in the amendments like "restructured loan", "shadow director", "financing activities", etc.
The document provides details of the specific sections amended and the new/amended definitions. In
The document summarizes key amendments made to the Patents and Designs Act, 1911 through the Patents and Designs (Amendment) Act, 2023. Some of the key changes include expanding the scope of patentable inventions, establishing patent offices and providing guidelines for granting patents. It also discusses procedures for filing and reviewing patents and establishing infringement and dispute resolution mechanisms.
This document establishes the formation of a new organization called the Digital Bangladesh Technology Park Authority (DBTPA) through an act of parliament. Some key points:
- DBTPA will be established as an autonomous government organization to support development of e-services, promote digital innovation, and help build an inclusive digital society.
- It will have the power to acquire and dispose of property, sue and be sued, and undertake any other necessary activities.
- DBTPA will be based in Dhaka but can establish branch offices elsewhere as needed with government approval.
- Its roles will include promoting tech innovation, research and development, awareness building, project implementation, advising government and others, and representing
1. The document is the additional issue of the Bangladesh Gazette dated October 17, 2023 published by the Government of Bangladesh containing official notices and advertisements.
2. It contains notices regarding registration of various documents under the Registration Act, 1908 as well as levy of stamp duty on certain instruments under the Stamp Act, 1899.
3. Details such as names of documents, registration fees to be paid, and stamp duty rates are provided in tabular format.
(1) The document discusses technical service fees charged for providing various technical services to foreign entities. It provides definitions and examples of different types of technical fees - professional service fees, technical service fees, technical know-how or technical assistance fees.
(2) Guidelines are given on calculating the rate for technical service fees, which is the number of foreign employees multiplied by a certain percentage of their salary. Registration of agreements related to technical service fees must be done according to the Registration Act.
(3) Examples are given of technical services that can be provided and the types of technical fees that can be charged for those services.
বাংলাদেশের অর্থনৈতিক সমীক্ষা ২০২৪ [Bangladesh Economic Review 2024 Bangla.pdf] কম্পিউটার , ট্যাব ও স্মার্ট ফোন ভার্সন সহ সম্পূর্ণ বাংলা ই-বুক বা pdf বই " সুচিপত্র ...বুকমার্ক মেনু 🔖 ও হাইপার লিংক মেনু 📝👆 যুক্ত ..
আমাদের সবার জন্য খুব খুব গুরুত্বপূর্ণ একটি বই ..বিসিএস, ব্যাংক, ইউনিভার্সিটি ভর্তি ও যে কোন প্রতিযোগিতা মূলক পরীক্ষার জন্য এর খুব ইম্পরট্যান্ট একটি বিষয় ...তাছাড়া বাংলাদেশের সাম্প্রতিক যে কোন ডাটা বা তথ্য এই বইতে পাবেন ...
তাই একজন নাগরিক হিসাবে এই তথ্য গুলো আপনার জানা প্রয়োজন ...।
বিসিএস ও ব্যাংক এর লিখিত পরীক্ষা ...+এছাড়া মাধ্যমিক ও উচ্চমাধ্যমিকের স্টুডেন্টদের জন্য অনেক কাজে আসবে ...
ISO/IEC 27001, ISO/IEC 42001, and GDPR: Best Practices for Implementation and...PECB
Denis is a dynamic and results-driven Chief Information Officer (CIO) with a distinguished career spanning information systems analysis and technical project management. With a proven track record of spearheading the design and delivery of cutting-edge Information Management solutions, he has consistently elevated business operations, streamlined reporting functions, and maximized process efficiency.
Certified as an ISO/IEC 27001: Information Security Management Systems (ISMS) Lead Implementer, Data Protection Officer, and Cyber Risks Analyst, Denis brings a heightened focus on data security, privacy, and cyber resilience to every endeavor.
His expertise extends across a diverse spectrum of reporting, database, and web development applications, underpinned by an exceptional grasp of data storage and virtualization technologies. His proficiency in application testing, database administration, and data cleansing ensures seamless execution of complex projects.
What sets Denis apart is his comprehensive understanding of Business and Systems Analysis technologies, honed through involvement in all phases of the Software Development Lifecycle (SDLC). From meticulous requirements gathering to precise analysis, innovative design, rigorous development, thorough testing, and successful implementation, he has consistently delivered exceptional results.
Throughout his career, he has taken on multifaceted roles, from leading technical project management teams to owning solutions that drive operational excellence. His conscientious and proactive approach is unwavering, whether he is working independently or collaboratively within a team. His ability to connect with colleagues on a personal level underscores his commitment to fostering a harmonious and productive workplace environment.
Date: May 29, 2024
Tags: Information Security, ISO/IEC 27001, ISO/IEC 42001, Artificial Intelligence, GDPR
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Reimagining Your Library Space: How to Increase the Vibes in Your Library No ...Diana Rendina
Librarians are leading the way in creating future-ready citizens – now we need to update our spaces to match. In this session, attendees will get inspiration for transforming their library spaces. You’ll learn how to survey students and patrons, create a focus group, and use design thinking to brainstorm ideas for your space. We’ll discuss budget friendly ways to change your space as well as how to find funding. No matter where you’re at, you’ll find ideas for reimagining your space in this session.
This presentation includes basic of PCOS their pathology and treatment and also Ayurveda correlation of PCOS and Ayurvedic line of treatment mentioned in classics.
Chapter wise All Notes of First year Basic Civil Engineering.pptxDenish Jangid
Chapter wise All Notes of First year Basic Civil Engineering
Syllabus
Chapter-1
Introduction to objective, scope and outcome the subject
Chapter 2
Introduction: Scope and Specialization of Civil Engineering, Role of civil Engineer in Society, Impact of infrastructural development on economy of country.
Chapter 3
Surveying: Object Principles & Types of Surveying; Site Plans, Plans & Maps; Scales & Unit of different Measurements.
Linear Measurements: Instruments used. Linear Measurement by Tape, Ranging out Survey Lines and overcoming Obstructions; Measurements on sloping ground; Tape corrections, conventional symbols. Angular Measurements: Instruments used; Introduction to Compass Surveying, Bearings and Longitude & Latitude of a Line, Introduction to total station.
Levelling: Instrument used Object of levelling, Methods of levelling in brief, and Contour maps.
Chapter 4
Buildings: Selection of site for Buildings, Layout of Building Plan, Types of buildings, Plinth area, carpet area, floor space index, Introduction to building byelaws, concept of sun light & ventilation. Components of Buildings & their functions, Basic concept of R.C.C., Introduction to types of foundation
Chapter 5
Transportation: Introduction to Transportation Engineering; Traffic and Road Safety: Types and Characteristics of Various Modes of Transportation; Various Road Traffic Signs, Causes of Accidents and Road Safety Measures.
Chapter 6
Environmental Engineering: Environmental Pollution, Environmental Acts and Regulations, Functional Concepts of Ecology, Basics of Species, Biodiversity, Ecosystem, Hydrological Cycle; Chemical Cycles: Carbon, Nitrogen & Phosphorus; Energy Flow in Ecosystems.
Water Pollution: Water Quality standards, Introduction to Treatment & Disposal of Waste Water. Reuse and Saving of Water, Rain Water Harvesting. Solid Waste Management: Classification of Solid Waste, Collection, Transportation and Disposal of Solid. Recycling of Solid Waste: Energy Recovery, Sanitary Landfill, On-Site Sanitation. Air & Noise Pollution: Primary and Secondary air pollutants, Harmful effects of Air Pollution, Control of Air Pollution. . Noise Pollution Harmful Effects of noise pollution, control of noise pollution, Global warming & Climate Change, Ozone depletion, Greenhouse effect
Text Books:
1. Palancharmy, Basic Civil Engineering, McGraw Hill publishers.
2. Satheesh Gopi, Basic Civil Engineering, Pearson Publishers.
3. Ketki Rangwala Dalal, Essentials of Civil Engineering, Charotar Publishing House.
4. BCP, Surveying volume 1
This presentation was provided by Steph Pollock of The American Psychological Association’s Journals Program, and Damita Snow, of The American Society of Civil Engineers (ASCE), for the initial session of NISO's 2024 Training Series "DEIA in the Scholarly Landscape." Session One: 'Setting Expectations: a DEIA Primer,' was held June 6, 2024.
हिंदी वर्णमाला पीपीटी, hindi alphabet PPT presentation, hindi varnamala PPT, Hindi Varnamala pdf, हिंदी स्वर, हिंदी व्यंजन, sikhiye hindi varnmala, dr. mulla adam ali, hindi language and literature, hindi alphabet with drawing, hindi alphabet pdf, hindi varnamala for childrens, hindi language, hindi varnamala practice for kids, https://www.drmullaadamali.com
it describes the bony anatomy including the femoral head , acetabulum, labrum . also discusses the capsule , ligaments . muscle that act on the hip joint and the range of motion are outlined. factors affecting hip joint stability and weight transmission through the joint are summarized.
How to Fix the Import Error in the Odoo 17Celine George
An import error occurs when a program fails to import a module or library, disrupting its execution. In languages like Python, this issue arises when the specified module cannot be found or accessed, hindering the program's functionality. Resolving import errors is crucial for maintaining smooth software operation and uninterrupted development processes.
Double Taxation Agreement between India and Bangladesh
1. Double Taxation Agreement between
India and Bangladesh
Signed on May 27, 1992
This document was downloaded from the Dezan Shira & Associates’ Online Library and was compiled by
the tax experts at Dezan Shira & Associates (www.dezshira.com).
Dezan Shira & Associates is a specialist foreign direct investment practice, providing corporate
establishment, business advisory, tax advisory and compliance, accounting, payroll, due diligence and
financial review services to multinationals investing in emerging Asia.
Established in 1999, Asia Briefing Ltd. (www.asiabriefing.com) is a Dezan Shira & Associates wholly-
owned subsidiary dedicated to providing individuals and enterprises with the latest business and
regulatory news as well as expert commentary relating to conducting business in emerging Asia.!
2. Bangladesh
Double Taxation Avoidance Agreement
Bangladesh
Income-tax Act, 1961: Notification under section 90: Double taxation agreement between India and
Bangladesh
Notification No. G. S. R. 758(E), dtd. 8.09.1992.
Whereas the annexed Convention between the Government of the Republic of India and the Government
of the People's Republic of Bangladesh for the avoidance of double taxation and the prevention of fiscal
evasion with respect to taxes on income has come into force on the 27th May, 1992, after the exchange
of Instruments of Ratification as required by paragraph 1 of article 31 of the said Convention;
Now, therefore, in exercise of the powers conferred by section 90 of the Income-tax Act, 1961 (43 of
1961), the Central Government hereby directs that all the provisions of the said Convention shall be given
effect to in the Union of India.
ANNEXURE
CONVENTION BETWEEN THE GOVERNMENT OF THE REPUBLIC OF INDIA AND THE
GOVERNMENT OF THE PEOPLE'S REPUBLIC OF BANGLADESH FOR THE AVOIDANCE OF
DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON
INCOME
The Government of the Republic of India and the Government of the People's Republic of Bangladesh,
Desiring to conclude a Convention for the avoidance of double taxation and the prevention of fiscal
evasion with respect to taxes on income,
Have agreed as follows:
CHAPTER I
SCOPE OF THE CONVENTION
Article 1
PERSONAL SCOPE
This Convention shall apply to persons who are residents of one or both of the Contracting States.
Article 2
TAXES COVERED
1. The existing taxes to which this Convention shall apply are--
a. In the case of Bangladesh:
the income-tax,
(hereinafter referred to as "Bangladesh tax");
b. In the case of India:
i. the income-tax including any surcharge thereon;
ii. the surtax;
3. (hereinafter referred to as "Indian tax").
2. This Convention shall also apply to any identical or substantially similar taxes which are imposed
by either Contracting State after the date of signature of the present Convention in addition to, or
in place of, the taxes referred to in paragraph (1). The competent authorities of the Contracting
States shall notify each other of any substantial changes which are made in their respective
taxation laws.
CHAPTER II
DEFINITIONS
Article 3
GENERAL DEFINITIONS
1. In this Convention, unless the context otherwise requires:
a. the term " Bangladesh " means the People's Republic of Bangladesh;
b. the term "India" means the Republic of India;
c. the terms " a Contracting State " and " the other Contracting State " mean Bangladesh or
India as the context requires;
d. the term " tax " means Bangladesh tax or Indian tax, as the context requires;
e. the term " person " includes an individual, a company and any other entity which is treated as
a taxable unit under the tax laws in force in the respective Contracting States;
f. the term " company " means any company, body corporate or any other entity which is
treated as a company under the tax laws of the respective Contracting States;
g. the terms " resident of a Contracting State " and " resident of the other Contracting State "
mean a person who is a resident of Bangladesh or a person who is a resident of India, as the
context requires;
h. the terms " enterprise of a Contracting State " and " enterprise of the other Contracting State "
mean respectively an enterprise carried on by a resident of a Contracting State and an
enterprise carried on by a resident of the other Contracting State;
i. the term "nationals" means all individuals possessing the nationality of the respective
Contracting States and also all legal persons, partnerships and associations deriving their
status as such from the law in force in the respective Contracting States;
j. the term " competent authority " means in the case of Bangladesh, the National Board of
Revenue or their authorised representative and in the case of India, the Central Government
in the Ministry of Finance (Department of Revenue) or their authorised representative;
k. the term " international traffic " means any transport by a ship or aircraft operated by an
enterprise of a Contracting State, except when the ship or aircraft is operated solely between
places in the other Contracting State;
2. As regards the application of this Convention by a Contracting State any term not otherwise
defined shall, unless the context otherwise requires, have the meaning which it has under the
laws of that Contracting State relating to the taxes which are the subject of this Convention.
Article 4
RESIDENT
1. For the purposes of this Convention, the term " resident of a Contracting State " means any
person who, under the law of that State, is liable to taxation therein by reason of his domicile,
residence, place of management or any other criterion of a similar nature.
2. Where by reason of the provisions of paragraph (1) an individual is a resident of both Contracting
States, then his case shall be determined in accordance with the following rules:
a. He shall be deemed to be a resident of the Contracting State in which he has a
permanent home available to him. If he has a permanent home available to him in both
4. Contracting States, he shall be deemed to be a resident of the Contracting State with
which his personal and economic relations are the closest (centre of vital interests);
b. If the Contracting State in which he has his centre of vital interests cannot be determined,
or if he has not a permanent home available to him in either Contracting State, he shall
be deemed to be a resident of the Contracting State in which he has an habitual abode;
c. If he has an habitual abode in both Contracting States or in neither of them he shall be
deemed to be a resident of the Contracting State of which he is a national;
d. If he is a national of both Contracting States or of neither of them, the competent
authorities of the Contracting States shall settle the question by mutual agreement.
3. Where by reason of the provisions of paragraph (1) a person other than an individual is a resident
of both Contracting States, then it shall be deemed to be a resident of the Contracting State in
which its place of effective management is situated.
Article 5
PERMANENT ESTABLISHMENT
1. For the purposes of this Convention, the term "permanent establishment" means a fixed
place of business in which the business of the enterprise is wholly or partly carried on.
2. The term "permanent establishment" shall include especially:
a. a place of management;
b. a branch;
c. an office;
d. a factory;
e. a workshop;
f. a warehouse;
g. a mine, quarry or other place of extraction of natural resources;
h. a building site or construction or assembly project or the like which exists for more than
183 days.
3. The term " permanent establishment " shall not be deemed to include:
a. the use of facilities solely for the purposes of storage or display of goods or merchandise
belonging to the enterprise;
b. the maintenance of a stock of goods or merchandise belonging to the enterprise solely
for the purpose of storage or display;
c. the maintenance of a stock of goods or merchandise belonging to the enterprise solely
for the purpose of processing by another enterprise;
d. the maintenance of a fixed place of business solely for the purpose of purchasing goods
or merchandise, or for collecting information, for the enterprise
e. the maintenance of a fixed place of business solely for the purpose of advertising, for the
supply of information, for scientific research or for similar activities which have a
preparatory or auxiliary character for the enterprise.
4. Notwithstanding the provisions of paragraphs (1) and (2), where a person--other than an
agent of an independent status to whom paragraph (5) applies--is acting in a Contracting
State on behalf of an enterprise of the other Contracting State, that enterprise shall be
deemed to have a permanent establishment in the first-mentioned State, if--
a. he has, and habitually exercises, in the first-mentioned State a general authority to
conclude contracts for or on behalf of the enterprise, unless his activities are limited to
the purchase of goods or merchandise for the enterprise, or
b. he habitually maintains in the first-mentioned State a stock of goods or merchandise
belonging to the enterprise from which that person regularly delivers goods or
merchandise for or on behalf of the enterprise, or
c. he habitually secures orders in the first-mentioned State, wholly or almost wholly, for the
enterprise itself, or for the enterprise or other enterprises which are controlled by it or
have controlling interest in it.
5. An enterprise of a Contracting State shall not be deemed to have a permanent establishment
in the other Contracting State merely because it carries on business in that other State
5. through a broker, general commission agent or any other agent of an independent status,
where such persons are acting in the ordinary course of their business and their activities do
not fall within the scope of paragraph (4)(c) above.
6. The fact that a company which is a resident of a Contracting State controls or is controlled by
a company which is a resident of the other Contracting State, or which carries on business in
that other State (whether through a permanent establishment or otherwise) shall not of itself
make either company a permanent establishment of the other.
7. An enterprise of a Contracting State shall be deemed to have a permanent establishment in
the other Contracting State if it carries on a business which consists of providing the services
of public entertainers (such as stage, motion picture, radio or television artistes and
musicians) or athletes in that other Contracting State unless such services are provided
within the scope of a cultural or sports exchange programme agreed or by both the
Contracting States.
CHAPTER III
TAXATION OF INCOME
Article 6
INCOME FROM IMMOVABLE PROPERTY
1. Income from immovable property shall be taxable only in the Contracting State in which
such property is situated.
2. The term " immovable property " shall be defined in accordance with the law and usage
(having the force of law) of the Contracting State in which the property in question is
situated. The term shall in any case include property accessory to immovable property,
livestock and equipment used in agriculture, forestry and fishery rights to which the
provisions of general law respecting landed property apply, usufruct of immovable
property and rights to variable or fixed payments in cash or kind as consideration for the
working of, or the right to work, mineral deposits, sources and other natural resources;
ships and aircraft shall not be regarded as immovable property.
3. The provisions of paragraph (1) shall apply to income derived from the direct use, letting,
or use in any other form of immovable property.
4. The provisions of paragraphs (1) and (3) shall also apply to the income from immovable
property of an enterprise and to income from immovable property used for the
performance of independent personal services.
Article 7
BUSINESS PROFITS
1. The profits of an enterprise of a Contracting State shall be taxable only in that State
unless the enterprise carries on business in the other Contracting State through a
permanent establishment situated therein. If the enterprise carries on business as
aforesaid, then so much of the profits of the enterprise as is attributable to that
permanent establishment shall be taxable only in that other Contracting State.
2. Where an enterprise of a Contracting State carries on business in the other Contracting
State through a permanent establishment situated therein, there shall in each Contracting
State be attributed to that permanent establishment the profits which it might be expected
to make if it were a distinct and separate enterprise engaged in the same or similar
activities under the same or similar conditions and dealing wholly independently with the
enterprise of which it is a permanent establishment. In any case, where the correct
amount of profits attributable to a perrmanent establishment is incapable of determination
or the ascertainment thereof presents exceptional difficulties, the profits attributable to the
permanent establishment may be computed on a reasonable basis.
6. 3. In the determination of the profits of a permanent establishment, there shall be allowed
as deductions expenses which are incurred for the purpose of the permanent
establishment including executive and general administrative expenses so incurred,
whether in the State in which the permanent establishment is situated or elsewhere, but
this does not include any expenses which, under the law of that State, would not be
allowed to be deducted by an enterprise of that State.
4. In so far as it has been customary in a Contracting State to determine the profits to be
attributed to a permanent establishment on the basis of an apportionment of the total
profits of the enterprise to its various parts, nothing in paragraph (2) shall preclude that
Contracting State from determining the Profits to be taxed by such an apportionment as
may be customary; the method of apportionment adopted shall, however, be such that
the result shall be in accordance with the principles laid down in this Article.
5. No profits shall be attributed to a permanent establishment by reason of the mere
purchase by that permanent establishment of goods or merchandise for the enterprise.
6. For the purpose of the preceding paragraphs, the profits to be attributed to the permanent
establishment shall be determined by the same method year by year unless there is good
and sufficient reason to the contrary.
7. Where profits include items of income which are dealt with separately in other Articles of
this Convention, then the provisions of those Articles shall not be affected by the
provisions of this Article.
Article 8
AIR TRANSPORT
1. Profits derived by an enterprise of a Contracting State from the operation of aircraft in
international traffic shall be taxable only in that Contracting State.
2. The provisions of paragraph (1) shall likewise apply in respect of income derived from
participation in pools of any kind by enterprises engaged in air transport.
Article 9
SHIPPING
1. Profits of an enterprise of a Contracting State derived from the other Contracting State
from the operation of ships in international traffic may be taxed in that other Contracting
State, but the tax chargeable in that other Contracting State on such income shall be
reduced by an amount equal to fifty per cent. of such tax.
2. The provisions of paragraph 1 shall also apply to profits derived from the participation in a
pool, a joint business or an international operating agency.
Article 10
ASSOCIATED ENTERPRISES
Where --
1. an enterprise of a Contracting State participates directly or indirectly in the management,
control or capital of an enterprise of the other Contracting State, or
2. the same persons participate directly or indirectly in the management, control or capital of an
enterprise of a Contracting State and an enterprise of the other Contracting State,
and in either case conditions are made or imposed between the two enterprises in their commercial or
financial relations which differ from those which would be made between independent enterprises, then
any profits which would, but for those conditions have accrued to one of the enterprises, but by reason of
those conditions, have not so accrued, may be included in the profits of that enterprise and taxed
accordingly.
7. Article 11
DIVIDENDS
1. Dividends paid by a company which is a resident of a Contracting State to a resident of the
other Contracting State may be taxed in that other Contracting State.
2. However, such dividends may also be taxed in the Contracting State of which the company
paying the dividends is a resident and according to the laws of that Contracting State, but if
the recipient is the beneficial owner of the dividends, the tax so charged shall not exceed:
a. 10 per cent. of the gross amount of the dividends if the beneficial owner is a company
which holds directly at least 10 per cent. of the capital of the company paying the
dividends;
b. 15 per cent. of the gross amount of the dividends in all other cases.
This paragraph shall not affect the taxation of the company in respect of the profits out of which the
dividends are paid.
3. The term " dividends " as used in this Article means income from shares, mining shares,
founder's shares or other rights, not being debt-claims, participating in profits, as well as income
from other corporate rights which is subjected to the same taxation treatment as income from
shares by the laws of the State of which the company making the distribution is a resident.
4. The provisions of paragraphs (1) and (2) shall not apply if the beneficial owner of the dividends,
being a resident of a Contracting State, carries on business in the other Contracting State of
which the company paying the dividends is a resident, through a permanent establishment
situated therein, or performs in that other State independent personal services from a fixed base
situated therein and the holding in respect of which the dividends are paid is effectively connected
with such permanent establishment or fixed base. In such case the provisions of Article 7 or
Article 15, as the case may be, shall apply.