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Agreement for avoidance of Double Taxation of income of Enterprises operating Aircraft between the Government of the Republic of India and the Government of Ethiopia

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..... the requirements have been completed in Ethiopia and India as are necessary to give the said Agreement 2 [ the force ] of law in Ethiopia and India respectively, as required by paragraph 1 of Article 3 of the said Agreement; And whereas the letters to this effect have been exchanged between the said two Governments, as required by paragraph 1 of Article 3 of the said Agreement; Now, therefore, in exercise of the powers conferred by section 90 of the Income-tax Act, 1961 (43 of 1961), and section 24A of the Companies (Profits) Surtax Act, 1964 (7 of 1964), the Central Government hereby directs that all the provisions of the said Agreement shall be given effect to in the Union of India. Annexure 3 [AGREEMENT BETWEEN .....

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..... the Agreement dated 3rd August, 1967 (as amended or revised from time to time) between the Government of India and the Government of Ethiopia relating to air services; or (ii) an airline which is authorised by the Government of that State by a general or special arrangement between the two Contracting States to operate chartered flights between or beyond their territories; (e) the term international traffic means any transport by an aircraft operated by an enterprise of a Contracting State, except when the aircraft is operated solely between places in the other Contracting State; and (f) the expression operation of aircraft means a business of transportation by air of persons, livestock, goods or mail, carried on by the own .....

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..... e in each of the Contracting States. It shall enter into force on the date of the exchange of letters certifying that the proper procedure was fulfilled in each Contracting State. The exchange of letters shall take place at Addis Ababa as soon as possible. 2. This Agreement shall have effect: (a) In Ethiopia, in respect of income derived from the operation of aircraft in international traffic after 1st July, 1966. (b) In India, in respect of income derived from the operation of aircraft in international traffic after 1st July, 1966. Article 4 This Agreement shall continue in effect indefinitely but may be terminated by either of the Contracting States with a written notice of six months. In such event, the Agreement shall c .....

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..... the said Agreement provides for the exemption from tax in either Contracting State of the income derived by an enterprise of the other Contracting State from operation of aircraft in international traffic after 1st July, 1966, the two Contracting States have agreed as follows: (1) Ethiopian Airlines being an enterprise of Ethiopia, any taxes paid by it or any deposits made by it towards its tax dues in India in respect of its income for which it is exempt from tax in accordance with the Agreement aforesaid shall be refunded by the Government of India to Ethiopian Airlines on an application in this behalf by Ethiopian Airlines within six months from the date on which the Agreement aforesaid enters into force, and any proceedings already i .....

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..... y between the Government of India and the Government of Ethiopia for the avoidance of double taxation of income of enterprises operating aircraft, I have the honour to state on behalf of the Government of India that whereas the said Agreement provides for the exemption from tax in either Contracting State of the income derived by an enterprise of the other Contracting State from operation of aircraft in international traffic after 1st July, 1966, the two Contracting States have agreed as follows: (1) Ethiopian Airlines being an enterprise of Ethiopia, any taxes paid by it or any deposits made by it towards its tax dues in India in respect of its income for which it is exempt from tax in accordance with the Agreement aforesaid shall be re .....

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..... BERHANE, S. A. DENEKE To SHRI PRANAB KUMAR MUKHERJEE Minister of Revenue and Banking, Government of India, New Delhi. ******* Notes 1. Substituted vide Notification No.0159[E] dated 02-03-1978 before it was read as . 2. Substituted vide Notification No.0159[E] dated 02-03-1978 before it was read as has force 3. Substituted vide Notification No.0159[E] dated 02-03-1978 before it was read as has force AGREEMENT BETWEEN THE GOVERNMENT OF THE REPUBLIC OF INDIA FOR The Avoidance of Double Tax .....

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