Double Taxation Avoidance Agreement Between India And United Arab Emirates
The Protocol amends Article 13 of the Tax Convention as regards source-based taxation. Among the amendments, the clause states that an enterprise established in a Contracting State is not entitled to the benefits of the tax treaty if the main purpose or one of the main objectives of the establishment of the enterprise was to preserve the benefits of the contract (i.e. management companies). It should be borne in mind that the Protocol does not specify what a management undertaking is or which States take the decision. The Protocol introduces a clause on the limitation of benefits, which has been inserted as Article 29 of the Tax Convention (note: Articles 29, 30 and 31 of the Tax Convention are noted in Articles 30, 31 and 32 respectively). (ii) extended time limit for the mutual agreement procedure (MAGP). . The sole purpose of the synthesized text is to facilitate the understanding and consistent interpretation of the impact of MLI on the DTAA of the Vae – India. The Government of India has recently published the consolidated text of the DTAA VAE – India, which contains amendments made by the SYNTHESISED TEXT OF THE MLI OF THE MULTILATERAL AGREEMENT ON THE IMPLEMENTATION OF FISCAL MEASURES TO PREVENT PROFIT REDUCTION AND PROFIT SHIFTING (MLI) AND THE AGREEMENT BETWEEN THE GOVERNMENT. The protocol also considers states, political subdivisions, etc., to be “residents.” Abu Dhabi Investment Authority is expressly recognized as a “resident” of the United Arab Emirates. Among the changes made to the DTAA, the most significant change is the inclusion of PPT.
Therefore, each company established in the United Arab Emirates should assess whether its main purpose corresponds to its functional profile. This continues to grow in importance, given recent substance requirements and country-by-country information rules in the UAE. These developments, combined with changes to the DBAA, are part of the UAE`s obligation to meet the minimum profit reduction and profit shifting standards issued by the Organisation for Economic Co-operation and Development. . India and the United Arab Emirates (United Arab Emirates) signed a Protocol of 26 March 2007 which will become part of the Tax Convention between India and the United Arab Emirates of 29 April 1992. The following main provisions are listed: it should be noted, however, that the text does not constitute a legal source, i.e. for legal purposes. The provisions of the MLI are to be read in addition to the DBA. The Protocol amends Article 24(1) of the Tax Convention to also exempt the Government of India or the United Arab Emirates from capital gains tax that may arise under the amended Article 13. AGREEMENT ON THE PREVENTION OF DOUBLE TAXATION AND THE PREVENTION OF TAX EVASION WITH AFGHANISTAN While the Government of India and the Government of Afghanistan have concluded an agreement with Albania to avoid double taxation and prevent tax evasion, THE GOVERNMENT OF THE REPUBLIC OF INDIA IS A “consolidated text” with regard to taxes on income and capital. (DBA) and the Multilateral Instrument (MLI), as it applies to the DCM.
This text was published by the Government of India following a joint consultation with the Government of the United Arab Emirates (United Arab Emirates). It has been prepared in accordance with the reservations and communications relating to the OECD position submitted to the OECD depositary by the United Arab Emirates and India on 29 May 2019 and 25 June 2019 respectively, following the completion of the ratification procedure by both countries. . . .