Most tax treaties include a „Tiebreaker“ exam in which a dual resident is considered only a resident of one of the two tax regulations. 5. Dividends paid by a company established in one of the contracting states on which a person who is not domiciled in the other contracting state are exempt from tax in that other state, unless the shareholding for which the dividends are paid is in fact linked to a stable establishment or a fixed base in that other state. This paragraph does not apply to dividends paid by a company established in Australia for Australian tax purposes and also established in India for Indian tax purposes. DBAs with each country are slightly different and different types of income (employment, businesses, interest, rents, capital gains, etc.) can all have different tax rules. This initiative was launched as part of the OECD`s Base Erosion and Profit Shifting (BEPS) project and is expected to cover most international groups operating in Australia. The nature of the impact depends on your activity and the countries in which you operate, with the final application of specific double taxation conventions (DBAs) yet to be clarified by the OECD. b. with respect to that undertaking, the agent would have a stable establishment in that other contracting state in accordance with the principles set out in Article 5, the undertaking carried out by the agent is considered to be an activity carried out in that other contracting state by that resident through a stable establishment established in that Member State, and this share of the company`s profits is attributed to that establishment. 2. Where the income from the personal activity of an artist as such is not paid to that artist, but to another person, that income may be taxed, notwithstanding Articles 7, 14 and 15, in the contracting state in which the artist`s activities are carried out.
http://www.edv-petri.de/wp-content/uploads/2017/03/Logo-EDVBeratungPetri-300x255.png 0 0 piapetri http://www.edv-petri.de/wp-content/uploads/2017/03/Logo-EDVBeratungPetri-300x255.png piapetri2020-12-07 10:30:352020-12-07 10:30:35Double Taxation Agreement With Australia