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annex to 1986 agreement

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..... mic Co-operation and Development after the date of signature of this Agreement India would accept a rate lower than 30 per cent for the taxation of royalties or fees for technical services paid by a resident of India to a resident of that State, it is understood that such lower rate will automatically be applied for the taxation of royalties and fees for technical services paid by a resident of India to a resident of Canada where the royalties or fees for technical services are paid in respect of a right or property which is first granted, or under a contract which is signed, after the date of entry into force of the first-mentioned Agreement or Convention. 2. Subsequent to the signing of the Agreement with Canada, India has entered int .....

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..... Canada and India are reviewing their tax treaty and will be re-examining rates of non-resident withholding tax. Pending conclusion of those negotiations, this remission order will provide residents of India with the same rate of non-resident withholding tax on fees or royalties for technical services as it provided by India for residents of Canada on such fees or royalties. Statistics are not available on the annual levels of royalty payments distributed to Indian residents and the associated withholding taxes. Therefore, the annual revenue cost of a five percentage point reduction in the withholding tax levied on such royalties must be based on a breakdown of related but more aggregated data. Using the best information available, the .....

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..... with respect to the amount so paid or credited, if the reference to a rate of 30 per cent in paragraph 2 of Article 13 of the Agreement were read as a reference to a rate of 20 per cent. His Excellency the Governor General in Council, considering that it is in the public interest on the recommendation of the Minister of Finance pursuant to section 23(2) of the Financial Administration Act is pleased hereby to make the annexed Order respecting the remission of income-tax, interest and penalties on royalties or fees received from Canada by residents of India for technical services. Notification : No. GSR 635(E), dated 24-6-1992. Whereas paragraph 4 of the Protocol to the Agreement between the Government of India and the Government of .....

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