AVOIDANCE OF DOUBLE TAXATION. 1. The laws in force in either of the Contracting States will continue to govern the taxation of income in the respective Contracting States except where provisions to the contrary are made in this Agreement.
AVOIDANCE OF DOUBLE TAXATION. 1. Income derived from the operation of ships or aircraft in international traffic by an enterprise of a Party shall be taxable only in that Party.
2. Gains derived from the alienation of ships or aircraft or movable property pertaining to the operation of ships and aircraft in international traffic by an enterprise of a Party shall be taxable only in that Party.
3. The provisions of paragraphs 1 and 2 shall also apply to income and gains derived by an enterprise of a Party from the participation in a pool, a joint business or an international operating agency.
AVOIDANCE OF DOUBLE TAXATION. (1) Income and profits derived from the operation of aircraft in international traffic by an airline of one Contracting Party, including participation in a pool service, a joint air transport operation or an international operating agency, which are subject to tax in the area of that Contracting Party shall be exempt from income tax, profits tax and all other taxes on income and profits imposed in the area of the other Contracting Party.
(2) Capital and assets of an airline of one Contracting Party relating to the operation of aircraft in international traffic shall be exempt from taxes on capital and assets imposed in the area of the other Contracting Party.
(3) Gains from the alienation of aircraft operated in international traffic and movable property pertaining to the operation of such aircraft which are received by an airline of one Contracting Party, the income and profits of which according to paragraph (1) are taxable only in the area of that Contracting Party, shall be exempt from any tax on gains imposed in the area of the other Contracting Party.
(4) For the purposes of this Article:
(a) the term “income and profits” includes revenues and gross receipts from the operation of aircraft for the carriage of persons, livestock, goods, mail or merchandise in international traffic including:
(i) the charter or rental of aircraft if such charter or rental is incidental to the operation of aircraft in international traffic;
(ii) the sale of tickets or similar documents, and the provision of services connected with such carriage, for the airline itself or for other airlines, but in the latter case only if such sales or provisions of services are incidental to the operation of aircraft in international traffic; and
(iii) interest on funds directly connected with the operation of aircraft in international traffic;
AVOIDANCE OF DOUBLE TAXATION. 1. In the case of Australia, subject to the provisions of the law of Australia from time to time in force which relate to the allowance of a credit against Australian tax of tax paid in a country outside Australia (which shall not affect the general principle of this Article), East Timor tax paid under the law of East Timor and in accordance with this Taxation Code, whether directly or by deduction, in respect of income derived by a person who is a resident of Australia of the following types:
(a) dividends paid wholly or mainly out of profits, income or gains as referred to in paragraph 1 of Article 8;
(b) interest paid by a contractor as referred to in paragraph 2 of Article 9;
(c) royalties paid by a contractor as referred to in paragraph 2 of Article 10; or
(d) profits, income or gains after income tax as referred to in paragraph 5 of Article 8, shall be allowed as a credit against Australian tax payable in respect of that income.
2. In the case of East Timor, subject to the provisions of the law of East Timor from time to time in force which relate to the allowance of a credit against East Timor tax of tax paid in a country outside East Timor (which shall not affect the general principle of this Article), Australian tax paid under the law of Australia and in accordance with this Taxation Code, whether directly or by deduction, in respect of income derived by a person who is a resident of East Timor of the following types:
(a) dividends paid wholly or mainly out of profits, income or gains as referred to in paragraph 1 of Article 8;
(b) interest paid by a contractor as referred to in paragraph 2 of Article 9;
(c) royalties paid by a contractor as referred to in paragraph 2 of Article 10; or
(d) profits, income or gains after income tax as referred to in paragraph 5 of Article 8, shall be allowed as a credit against East Timor tax payable in respect of that income.
3. The dividends, interest or royalties taxed by a Contracting State in accordance with the provisions of this Taxation Code and referred to in this Article shall for the purposes of determining a foreign tax credit entitlement under the law of the other Contracting State, be deemed to be income derived from sources in the first-mentioned Contracting State.
AVOIDANCE OF DOUBLE TAXATION. Income or profits derived from the operation of aircraft in international traffic by an airline of one Contracting Party, including participation in a pool service, a joint air transport operation or an international operating agency, which are subject to tax in the area of that Contracting Party shall be exempt from income tax, profits tax and all other taxes on income or profits imposed in the area of the other Contracting Party.
AVOIDANCE OF DOUBLE TAXATION. 1. The laws in force in either of the Contracting States shall continue to govern the taxation of income in the respective Contracting States except where express provision to the contrary is made in this Agreement.
2. Where a resident of India derives income which, in accordance with the provisions of this Agreement, may be taxed in Singapore, India shall allow as a deduction from the tax on the income of that resident an amount equal to the Singapore tax paid, whether directly or by deduction. Where the income is a dividend paid by a company which is a resident of Singapore to a company which is a resident of India and which owns directly or indirectly not less than 25% of the share capital of the company paying the dividend, the deduction shall take into account the Singapore tax paid in respect of the profits out of which the dividend is paid. Such deduction in either case shall not, however, exceed that part of the tax (as computed before the deduction is given) which is attributable to the income which may be taxed in Singapore.
3. For the purposes of paragraph 2 of this Article, "Singapore tax paid" shall be deemed to include any amount of tax which would have been payable but for the reduction or exemption of Singapore tax granted under:
(a) the provisions of the Economic Expansion Incentives (Relief from Income Tax) Act and the provisions of sections 13(1)(t), 13(1)(u), 13(1)(v), 13(2), 13A, 00X, 00X, 00X, 00X, 14E, 00X, 00X, 00X, 00X, 00X, 00X, 00X, 43I, 43J and 43K of the Income Tax Act, insofar as they were in force and have not been modified since the date of signature of this Agreement, or have been modified in minor respects so as not to affect their general character;
(b) any other provisions which may subsequently be enacted granting an exemption or reduction of tax which is agreed by the competent authorities of the Contracting States to be of a substantially similar character to any provision referred to in subparagraph (a) of this paragraph, if such provision has not been modified thereafter or has been modified only in minor respects so as not to affect its general character.
4. Subject to the provisions of the laws of Singapore regarding the allowance as a credit against Singapore tax of tax paid in any country other than Singapore, Indian tax paid, whether directly or by deduction, in respect of income from sources within India shall be allowed as a credit against Singapore tax payable in respect of that income. Where such income is ...
AVOIDANCE OF DOUBLE TAXATION. 1. Income derived from the operation of aircraft in international traffic by an enterprise of a Contracting State shall be exempt from tax in the other Contracting State.
2. Gains derived by an enterprise of a Contracting State from the alienation of aircraft owned and operated by the enterprise in international traffic, the income from which is taxable only in that State, and gains from the alienation of spares, equipment, and other movable property used by the enterprise in the operation of such aircraft shall be exempt from tax in the other Contracting State.
AVOIDANCE OF DOUBLE TAXATION. 1. The law in force in either of the Contracting States will continue to govern the taxation of income in the respective Contracting States except where provisions to the contrary are made in this Agreement.
2. Where a resident of India derives income which, in accordance with the provisions of this Agreement, may be taxed in the Sultanate of Oman, India shall allow as a deduction from the tax on the income of that resident an amount equal to the income-tax paid in the Sultanate of Oman, whether directly or by deduction. Such deduction shall not, however, exceed that part of the income-tax (as computed before the deduction is given) which is attributable to the income which may be taxed in the Sultanate of Oman.
3. Where a resident of the Sultanate of Oman derives income which, in accordance with the provisions of this Agreement, may be taxed in India, the Sultanate of Oman shall allow as a deduction from the tax on the income of the resident an amount equal to the income-tax paid in India, whether directly or by deduction. Such deduction shall not, however, exceed that part of the income-tax (as computed before the deduction is given) which is attributable to the income which may be taxed in India.
4. The tax payable in a Contracting State mentioned in paragraph 2 and paragraph 3 of this article shall be deemed to include the tax which would have been payable but for the tax incentives granted under the laws of the Contracting State and which are designed to promote economic development.
5. Income which, in accordance with the provisions of this Agreement, is not to be subjected to tax in a Contracting State, may be taken into account for calculating the rate of tax to be imposed in that Contracting State.
AVOIDANCE OF DOUBLE TAXATION. 1. The laws in force in either of the Contracting State will continue to govern the taxation of income in the respective Contracting State except where provisions to the contrary are made in this Agreement.
2. Where a resident of India derives income or owns capital which, in accordance with the provisions of this Agreement, may be taxed in Uzbekistan, India shall allows as a deduction from the tax on the income of that resident an amount equal to the income-tax paid in Uzbekistan, whether directly or by deduction; and as a deduction from the tax on the capital of that resident an amount equal to the capital tax paid in Uzbekistan. Such deduction in either case shall not, however, exceed that part of income-tax or tax on capital (as paid before the deduction is given), which is attributable to the income or the capital which may be taxed in Uzbekistan.
3. In the case of Uzbekistan the double taxation shall be avoided by a method which is identical to that mentioned in paragraph 2.
4. The tax payable in the Contracting State mentioned in paragraphs 2 and 3 of this Article shall be deemed to include the tax which would have been payable but for the tax incentives granted under the laws of the Contracting State and which are designed to promote economic development.
5. Income which, in accordance with the provisions of this Agreement, is not to be subject to tax in a Contracting State, may be taken into account for calculating the rate of tax to be imposed in that Contracting State.
AVOIDANCE OF DOUBLE TAXATION. 1. In Chile, double taxation shall be avoided as follows:
(a) residents of Chile, obtaining income or owning capital which has, in accordance with the provisions of this Convention, been subject to taxation in South Africa, may credit the tax so paid against any Chilean tax payable in respect of the same income or capital, subject to the applicable provisions of the law of Chile (which shall not affect the general principle hereof). This paragraph shall apply to all income or capital referred to in this Convention;
(b) where, in accordance with any provision of this Convention, income derived or capital owned by a resident of Chile is exempt from tax in Chile, Chile may nevertheless, in calculating the amount of tax on other income or capital, take into account the exempted income or capital.
2. In South Africa, double taxation shall be avoided as follows: subject to the provisions of the law of South Africa regarding the deduction from tax payable in South Africa of tax payable in any country other than South Africa (which shall not affect the general principle hereof), Chilean tax paid by residents of South Africa in respect of income or capital taxable in Chile, in accordance with the provisions of this Convention, shall be deducted from the taxes due according to South African fiscal law. Such deduction shall not, however, exceed an amount which bears to the total South African tax payable the same ratio as the income or capital concerned bears to the total income or capital, as the case may be.
