Mondaq Asia Pacific: Tax > Tax Treaties
China Tax & Investment Consultants Ltd
In negotiating a tax treaty, both parties can discuss and cover every topic and insert it in the agreement or protocol.
China Tax & Investment Consultants Ltd
Note that this section illustrates how Article 16 works in practice from an Australian perspective.
China Tax & Investment Consultants Ltd
The following is Part 3 of the above captioned article that specifically deals with How contracting jurisdictions apply Article 16 to their CTA's.
China Tax & Investment Consultants Ltd
This paper will focus on Article 16 - mutual agreement procedure (the MAP) and will be organized in the following way:
China Tax & Investment Consultants Ltd
As the following table shows, a Signatory or Party to the Convention can choose to apply paragraph 4 either in addition to or to the exclusion of paragraph 1.
China Tax & Investment Consultants Ltd
Both Japan and Zealand opts in for Article 9(4), and both of the two contracting states have made notification to the Depositary, pursuant to Article 9(8) of the MLI.
China Tax & Investment Consultants Ltd
In Section IV, the article ends with a conclusion that one can learn from understanding the MLI as an international convention.
China Tax & Investment Consultants Ltd
It is observed that except for India, 4 other contracting parties have chosen to opt-in for Article 7(4).
China Tax & Investment Consultants Ltd
Article 6(1) sets the minimum standard for all Parties that have committed themselves to the OECD/G20 BEPS package.
TMF Group
If a non-domiciled individual is physically present on the mainland for 24 hours in one day, that day counts towards a day of residing in China.
TMF Group
China's aspirations for its aircraft finance sector are as lofty as its potential, as it bids to transform a young and fast-growing domestic industry into a world-beating one.
TMF Group
China has clarified the definition of beneficial owners in the provision of tax treaty dividends. The new requirements have been effective since 1 April 2018.
WTS China
中国颁布了11 号公告,阐明了税 收协定执行过程中的下列问题:
WTS China
Announcement 11 has declared an end to the twin approaches, and adopted 183 days as the threshold for all tax treaty implementation. The distinction between these two approaches is summarised below
STA Law Firm
While considering moving a business into a new market, one of the key consideration is that country's tax regime.
TMF Group
The aviation finance industry continues to expand across Asia, driven by booming air travel in China, India and other regional markets, causing a growing number of aircraft lessors to look at setting up operations...
Nishith Desai Associates
As per a media report, the Government of India is proposing to amend the existing Double Taxation Avoidance Agreement between India and Mauritius
Vaish Associates Advocates
DTAA (Double Taxation Avoidance Agreement) refers to a Tax Treaty that is entered between two countries. The purpose of such Agreements is to make sure that a person does not suffer duplication of taxes.
Nishith Desai Associates
The characterization of payments made for shrinkwrapped software has been a controversial issue in India, resulting in a large number of litigations.
Vaish Associates Advocates
Vaish Associates Budget 2019 presentation.
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China Tax & Investment Consultants Ltd
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STA Law Firm
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China Tax & Investment Consultants Ltd
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Nishith Desai Associates
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Nishith Desai Associates
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Nishith Desai Associates
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