section 90

Empowering Central Government to enter into agreement with specified non-sovereign territories & Transfer Pricing

Amendment of section 90 :-The Finance Bill (No. 2) 2009 proposes to replace the existing Section 90 with a new section 90. The new section 90 is substantially the same as earlier section 90 except that the proposed amendment seeks to empower the Central Government to enter into an agreement with the Government of any country outside India or a specified territory outside India, inter alia, for avoidance of double taxation of income.
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Taxability of a South Korean Company on basis of its Local office in India

If the LO is having decision making authority on behalf of the HO and also empowered to conclude the contract and to secure purchase orders. Then considering the activities carried on LO is to be treated as permanent establishment and will not be excluded from the definition of permanent establishment as per Article 5(4)(e) of DTAA.
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Agreement for Avoidance of Double Taxation and Prevention of Fiscal Evasion with Government of Grand Duchy of Luxembourg

NOTIFICATION NO. 78/2009 Whereas, an Agreement and the Protocol between the Government of Republic of India and the Government of the Grand Duchy of Luxembourg for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital was signed at New Delhi on the 2nd day of June, 2008;
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