TMI BlogAmendment in DTAT with Japan notified from June 28X X X X Extracts X X X X X X X X Extracts X X X X ..... oidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income shall enter into force on the 28th day of June, 2006 in accordance with paragraph 1 of Article V of the Protocol amending the Convention for giving effect to the provisions of the said Protocol; Now, therefore, in exercise of the powers conferred by section 90 of the Income-tax Act, 1961 (43 of 1961), ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he Government of Japan for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income signed at New Delhi on 7th March, 1989 (hereinafter referred to as the Convention), Have agreed as follows: ARTICLE I Paragraph 2 of Article 10 of the Convention shall be deleted and replaced by the following : 2. However, such dividends may also be taxed in th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the interest. ARTICLE III Paragraph 2 of Article 12 of the Convention shall be deleted and replaced by the following : 2. However, such royalties and fees for technical services may also be taxed in the Contracting State in which they arise and according to the laws of that Contracting State, but if the recipient is the beneficial owner of the royalties or fees for technical services, the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... r 1st January of the calendar year next following the year in which the Protocol enters into force, if the Protocol enters into force after 30th June of a calendar year; and ( ii ) with respect to taxes on income which are not withheld at source, as regards income for any taxable year beginning on or after 1st January of the calendar year next following that in which the Protocol enters into for ..... X X X X Extracts X X X X X X X X Extracts X X X X
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