TMI BlogTerminationX X X X Extracts X X X X X X X X Extracts X X X X ..... iven; (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 ..... several contracts have been entered into for the work being done, provided that if forms a coherent whole commercially and geographically; (b) 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 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he Government of the Republic of India for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on income and capital gains which has 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 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... erived from the reinvestment of such interest as being so included. If the foregoing proposal is acceptable to the Government of the Republic of India have the honour to suggest 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 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ouble Taxation Avoidance Agreement between Government of India and Government of U.K. came into force with effect from 23-11-1981 and assessee not resident who had made deposits in India prior to that date, renewed certain deposits after 23-11-1981, deposit so renewed were to be interpreted as loans first created within meaning of aforesaid agreement and interest on such deposits could be charged at rate of 15 per cent onlyBorhat Tea Co. Ltd. v. ITO [1990] 33 ITD 9 (Cal.) (SMC). - - statute, statutory provisions legislation, law, enactment, Acts, Rules, Regulations, Taxation Tax Management India - taxmanagementindia - taxmanagement - taxmanagementindia.com - TMI - TaxTMI - TMITax - Double Tax Avoidance Agreements, Tax Treaty, internatio ..... X X X X Extracts X X X X X X X X Extracts X X X X
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