5. Provisions to avoid tax evasion: they include Articles 9 (associated companies) and 26 (exchange of information). 7. Because of a special relationship between the payer and the actual beneficiary or between the two and another person, the amount of interest is greater than the amount that would have been agreed by the payer and the actual beneficiary in the absence of such a relationship. the provisions of this section apply only to the most recent amount. In this case, the excess portion of the payments remains taxable under the legislation of each contracting state, taking into account the other provisions of the agreement. Double taxation agreements (also known as double taxation agreements or “DBAA”) are negotiated under international law and are governed by the principles of the Hague Convention. Dear Sir, we had provided services to one of our customers in Zambia and our bill to the tune of Now we learned that the customer said he was going to pay 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 2.
When income from activities carried out by an artist or athlete in his or her capacity as such is not paid to the artist or athlete, but to another person, this income may be taxed on that other person, notwithstanding the provisions of section 7 (commercial profits), 15 (Independent Personal Services) and 16 (Dependant Services) in the contracting state in which the activities of the artist or athlete are carried out unless the artist , the athlete or any other person who proves that neither the artist, the athlete nor the associated persons directly or indirectly participate in that other person`s profits, including receipt of deferred allowances, bonuses, fees, dividends, partnership distributions or other distributions.