If a resident of one of the territories proves that the action of the tax authorities in the other territory has resulted in or will result in double taxation contrary to the provisions of this Convention, he is entitled to present his case to Mr. Darwed, we have provided services to one of our clients in Zambia and our bill is $. We learned that the client stated that he would make the payment after tax deduction. However, we are also in favour of paying income tax for the revenues of the above service. In this case, we have to pay twice as much tax for the same income. Can you advise us to avoid such double taxation? I want to know how to treat india`s DTAA 1. Where a person believes that the actions of one or both of the contracting states result in or lead to an imposition that does not comply with the provisions of this Convention, he may, regardless of the remedies provided by the domestic law of those States, bring his case to the competent authority of the contracting state, to his place of residence or, if his case falls under Article 24 , paragraph 1, of which he is a national. The case must not be brought in accordance with the provisions of this agreement within three years of the first notification of the measure leading to taxation. 5. The Tribunal also stated that a distinction had been made between a commercial relationship and a stable establishment. The latter is intended for the taxation of a non-resident`s income under a double taxation agreement, while the first applies to the application of the Income Tax Act.
With regard to offshore services, the Tribunal found that a sufficient territorial link between the transfer of services and India`s territorial borders was necessary to make income taxable. The entire contract would not be due to activities in India. The residence examination, also applied in international law, is that of the taxpayer and not that of the beneficiary of these services. 4. The competent authorities of the contracting states may, by mutual agreement, determine how the provisions of this agreement apply to exemption or reduction. NGOs can avoid paying double taxes under the Double Tax Avoidance Agreement (DTAA). Generally, non-resident Indians (NRIs) live abroad but earn income in India. In such cases, income collected in India may be taxed in India and the country of residence of the RNA. This means that they would have to pay twice taxes on the same income. To avoid this, the Double Tax Avoidance Agreement (DBAA) has been amended. The UN model gives more weight to the source principle than to the principle of residence in the OECD model. In conjunction with the principle of withholding tax, the article of the convention model assumes that: (a) the taxation of foreign capital income would take into account expenditures attributable to income income, so that these incomes would be taxed netly, (b) that the tax would not be high enough to discourage investment and (c) that it is the adequacy of revenue sharing with the country.
which provides the capital.