TMI BlogTerminationX X X X Extracts X X X X X X X X Extracts X X X X ..... ts entry into force. In such case, the Agreement shall cease to have effect : (a) in Turkey, for taxes with respect to every taxable year beginning on or after the first day of January of the year following that in which the notice of termination is given; (b) in India, for taxes with respect to every previous year beginning on or after the first day of April of the year following that in whic ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... shall not include any amount which is payable in respect of any default or omission in relation to the taxes to which this Agreement applies or which represents a penalty. With respect to proviso to sub-paragraph (j) of paragraph 2 of Article 5 2. It is understood that an enterprise covered therein will be subject to taxation accordingly and not in accordance with provisions of Article 12 (Ro ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... to a permanent establishment in India, it is understood that, the executive and general administrative expenses incurred outside India which will be allowed as a deduction in determining the profits of the permanent establishment shall be the least of the following amounts : (a) an amount equal to 5 per cent of the adjusted total income; or (b) an amount equal to the average head office expen ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ication of the ordinary taxation laws and regulations, in substantially similar circumstances both in law and in fact. Amongst other things this means that a national of one of the States, resident of a third State and doing business in the other State will be subjected to the same taxation or requirements connected therewith in that other State to which a national of that other State, resident ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
