TMI BlogAMENDMENT IN DTAA WITH SINGAPOREX X X X Extracts X X X X X X X X Extracts X X X X ..... 1961 (43 of 1961), the Central Government hereby directs that all the provisions of the said Protocol amending the Agreement between the Government of the Republic of India and the Government of the Republic of Singapore for The Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income shall be given effect to in the Union of India with effect from the 1st day of August, 2005. PROTOCOL AMENDING THE AGREEMENT BETWEEN THE GOVERNMENT OF THE REPUBLIC OF SINGAPORE AND THE GOVERNMENT OF THE REPUBLIC OF INDIA FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME SIGNED IN INDIA ON 24TH JANUARY 1994 The Government of the Republic of Singapore and the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... uit company is any legal entity falling within the definition of resident with negligible or nil business operations or with no real and continuous business activities carried out in that Contracting State. 3. A resident of a ContractingState is deemed to be a shell/conduit company if its total annual expenditure on operations in that ContractingState is less than S$200,000or Indian Rs. 50,00,000 in the respective ContractingState as the case may be, in the immediately preceding period of 24 months from the date the gains arise. 4. A resident of a ContractingState is deemed not to be a shell/conduit company if (a) it is listed on a recognised stock exchange of the ContractingState; or (b) its total annual expenditure on operations i ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... om the alienation of shares in any company which is a resident of a Contracting State shall be taxable only in the Contracting State in which the alienator is a resident. ARTICLE 7 This Protocol, which shall form an integral part of the Agreement, shall come into force on 1 August 2005. IN WITNESS WHEREOF, the undersigned, being duly authorized by their respective Governments, have signed this Protocol. Done at New Delhi, India, this twenty-ninth day of June 2005, in two originals in English language, each text being equally authentic. FOR THE GOVERNMENT OF THE REPUBLIC OF INDIA FOR THE GOVERNMENT OF THE REPUBLIC OF SINGAPORE - Notification Tax Management India - taxmanagementindia - taxmanagement - taxma ..... X X X X Extracts X X X X X X X X Extracts X X X X
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