India Italy Double Taxation Avoidance Agreement

(3) This Article shall not be construed as requiring a Contracting State to grant personal allowances, reductions and reductions to persons who are not resident in that State for tax purposes which, by law, are available only to persons domiciled. Other public bodies or bodies may also be included by mutual agreement between the competent authorities of the Contracting States in the above list;< In Italy, the risk of double taxation can be combated in different ways: the risk of double taxation is the result of conventions established by two States (such as Switzerland or Germany). as regards the taxation regime of the two States on the basis of the principle of reciprocity. These agreements are based on income tax and sometimes on inheritance items. The existence of several double taxation treaties is obviously not good (for example, a US-Italian tax treaty or an Italian-British double taxation convention), as it increases the risk of using them to avoid taxation through an "international non-taxation system", which creates the phenomenon of so-called "treaty abuse". 4. The competent authorities of the Contracting States may communicate directly with each other with a view to reaching an agreement within the meaning of the preceding paragraphs. If it appears desirable to reach agreement on an oral exchange of views, such an exchange may be carried out through a commission composed of representatives of the competent authorities of the States Parties. one. Referring to paragraph 3 of Article 7, "costs incurred for the purposes of the business of the permanent establishment" means expenses directly related to the business of the permanent establishment, as well as royalties, commissions and interest corresponding to the amount actually reimbursed of the expenses and, in both cases, admitted by the tax law of the State Party; By signing today the Convention on the Prevention of Double Taxation and the Prevention of Fiscal Evasion with Regard to Taxes on Income, concluded today between the Government of the Republic of Italy and the Government of the Republic of India, the undersigned have agreed on the following additional provisions, which form an integral part of the said Convention. . .


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