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Is it Time to Re–think the Indo–US Double Taxation Avoidance Agreement?

Intertax, 2008
In 1959 India attempted to enter into a Double Taxation Avoidance Treaty with the United States of America. The US Senate however rejected the treaty because the Indian Government had inserted into the treaty a provision regarding ‘tax sparing credits’.
exaly   +2 more sources

Double Taxation Avoidance Agreements

2021
Taxation of productive factors involves balancing national against international considerations. National objectives concern revenue, allocative efficiency and equity effects of taxation. Tax systems have fundamental ramifications also on the volume and allocation of productive resources internationally because factor returns and underlying tax bases ...
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The Tax Cooperation Mechanism between China and African Countries and the Avoidance of a Double Taxation Agreement

Comparative and International Law Journal of Southern Africa, 2023
The tax cooperation mechanism between China and African countries has a bearing on the business environment of bilateral economic and trade cooperation. At present, the tax cooperation mechanism between China and African countries has developed rapidly by way of the Forum on China-Africa Cooperation (FOCAC) and the Belt and Road Initiative (B&R ...
Zhang Zezhong, Xu Yue
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The China-Pakistan Avoidance of Double Taxation Agreement and the China-Pakistan Economic Corridor

Bulletin for International Taxation, 2018
In this article, the authors review the principal features of the China-Pakistan tax treaty and its impact on the China-Pakistan Economic Corridor project.
P. Mellor, N. Li, M.A. Ahmed
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Applicability of Double Taxation Avoidance Agreements to Fiscally Transparent Entities: An Indian Perspective

Intertax, 2011
Being 'liable to taxation' is a prerequisite for being a resident (under most double taxation avoidance agreements (DTAAs)). Therefore, fiscally transparent entities (as they do not pay taxes) would not be residents and thus would not be entitled to treaty benefits.
Anish Agarwal, Tarumoy Chaudhuri
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Concentrix Service Netherlands S.V.: Most Favoured Nation Clause in India’s Double Taxation Avoidance Agreements

Asia-Pacific Tax Bulletin, 2022
In this article, the author reviews the legal provisions and relevant court decisions relating to the most favoured nation clause in India’s double taxation avoidance agreements (DTAAs). He traces the origin and evolution of this clause in India’s DTAAs and discusses an important dispute that arose in the application of this clause and the position of ...
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How to Axe a Double Taxation Avoidance Agreement: Analysing Section 94A of the Indian Income Tax Act

Intertax, 2016
Section 94-A of the Indian Income Tax Act, which allows the Indian government (the executive) to notify any jurisdiction, by having regard to the lack of effective exchange of information with it, as a notified jurisdictional area (NJA) has been a bone of contention in a recent ruling delivered by the Madras High Court in India in T.
openaire   +1 more source

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