9911796707
TMI BlogTerminationX X X X Extracts X X X X X X X X Extracts X X X X ..... given; (ii) in respect of corporation tax, for any financial year beginning on or after 1st April in the calendar year next following that in which the notice is given; (iii) in respect of petroleum revenue tax, for any chargeable period beginning on or after 1st January in the calendar year next following that in which the notice is given; (b) in India, in respect of income arising in any fiscal year beginning on or after the first day of April next following the calendar year in which the notice given. In witness whereof the undersigned, duly authorised thereto by their respective Governments, have signed this Convention. Done on this 25th day of January, 1993, in New Delhi on two original copies each in the Hindi and English lan ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... that, in applying paragraph 3 of Article 7, for the purpose of determining whether a permanent establishment has taken an active part in negotiating, concluding or fulfilling contracts entered into by the enterprise, the Contracting States shall take into considerations all relevant circumstances and, in particular, the fact that a contract or order relating to the purchase or provision of goods or services was negotiated or placed with the head office of the enterprise, rather than with the permanent establishment, shall not preclude them from determining that the permanent establishment did take an active part in negotiating, concluding or fulfilling that contract; (c) that, in applying paragraph 1 of Article 8, for the purpose of deter ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... been signed today and to propose on behalf of the Government of the United Kingdom of Great Britain and Northern Ireland : (a) that, in applying sub-paragraph (j) of paragraph 2 of Article 5, for the purpose of determining whether a building site or construction, installation or assembly project or supervisory activity in connection therewith has continued for a period of more than six months, the Contracting States shall : (i) take no account of time previously spent by employees of the enterprise on other sites or projects which have no connection with the site or project in question; (ii) apply more than six months test separately to each site or project which has no connection with any other site or project and to each group of c ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... uggest that the present Note and Your Excellencys reply to that effect should be regarded as constituting an agreement between the two Government in this matter. In reply, I have the honour to state that the Government of the Republic of India accepts the proposal made therein and agrees that Your Excellencys Note and the present reply shall constitute an agreement between the Government of Republic of India and the Government of the United Kingdom of Great Britain and Northern Ireland in this matter. I avail myself of this opportunity to renew to Your Excellency the assurances of my highest consideration. (S. Ramamurti) Chairman Central Board of Direct Taxes India. His Excellency Sir Nicholas Fenn, KCMG British High Commission in I ..... X X X X Extracts X X X X X X X X Extracts X X X X
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