Home Acts & Rules DTAA Agreements France This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
Article 2 - Taxes covered - FranceExtract ARTICLE 2 - Taxes covered - 1. The taxes to which this Convention shall apply are : (a) in India : (i) the income-tax including any surcharge thereon ; (ii) the surtax ; and (iii) the wealth-tax, (hereinafter referred to as Indian tax) ; (b) in France : (i) the income-tax (1 impot sur le revenu) including any withholding tax, pre-payment (precompte) or advance payment with respect thereto ; (ii) the corporation tax (limpot sur les scietes) including any withholding tax, prepayment (precompte) and advance payment with respect thereto ; and (iii) the wealth-tax (I impot le solioaritesur la fortune). (hereinafter referred to as French tax). 2. The 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. (b) 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.
|