Double Tax Avoidance Agreement Between India And Netherlands

Three of them. In addition, the Netherlands allows a deduction of Dutch tax thus calculated for income that can be taxed in India in accordance with Article 8A, paragraph 2, paragraph 2, Article 12, paragraph 2, Article 17, paragraph 17, and Article 17, paragraph 2, of this agreement, to the extent that these elements are included in the basis of paragraph 1. The amount of this deduction corresponds to the tax paid in India on these income items, but cannot exceed the amount of reduction that would be allowed if the so-called income items were the only income items exempt from Dutch tax under the Dutch tax provisions to avoid double taxation. 2. If one of the States collects the profits that would have been made by the company of the first state and the taxes on which a company of the other State was imposed in that other state, are the profits that would have been incurred by the enterprise of the first state if the conditions imposed between the two enterprises had been between independent enterprises and between independent enterprises and between independent enterprises. , this other state makes an appropriate correction of the amount of tax on these profits. The other provisions of this Convention are duly taken into account in determining this correction and the competent authorities of the States consult, if necessary. A. In determining the profits of a stable establishment, upstream deductions are permitted for the purpose of stable establishment, including administrative expenses incurred, in the state in which the establishment is located or in any other location, in accordance with the provisions and subject to the limitations imposed by the tax laws of that state. Where the law of the state in which the establishment is established imposes a limitation on the level of authorized administrative and general administrative costs and that restriction is relaxed or repealed by an agreement between that state and a third state that will enter into force after the entry into force of this convention, and that limitation is subject to an agreement between that state and a third state when the entry into force of this convention enters into force.

force, relaxed or is repealed, the competent authority of that State notifies the competent authority of the other State, as soon as this Convention comes into force, the provisions of the corresponding paragraph contained in the convention with that third country and, if the competent authority of the other State requests it, the provisions of this paragraph are amended by a protocol to take these conditions into account.