(f) the concept of “company”: any entity or entity that is considered an entity or entity under the tax legislation of the contracting states concerned; This paragraph does not affect the corporation`s taxation on the profits on which the dividends are paid. These agreements are based on income tax and, sometimes, on estate elements. (d) if he is a national of the two contracting states or of one of those contracting states, the competent authorities of the contracting states resolve the matter by mutual agreement. The existence of several agreements against double taxation is obviously not a good thing (for example. B, a tax treaty between the United States and Italy or a double taxation agreement between Italy and the United Kingdom), because it increases the risk of using them to avoid taxation through a “dual international non-taxation regime,” thus creating the phenomenon of so-called “treaty abuse.” Other public bodies or bodies may also be placed on the above list by mutual agreement between the relevant authorities of the States Parties; < 2. The competent authority endeavours, when the objection seems justified and is not in a position to find an appropriate solution itself to resolve the matter by mutual agreement with the competent authority of the other State party, in order to avoid taxation that is not in accordance with the convention. 1. Where a resident of a contracting state considers that the actions of one or both of the contracting states result in or lead to an imposition that does not comply with the provisions of this Convention, he may, notwithstanding the remedies provided by the national law of those States, submit his case to the competent authority of the contracting state of which he is domiciled. The application must be made within two years of the date of taxation or withholding tax, with the latest date being withheld. At the signing of today`s agreement between the Government of the Italian Republic and the Government of the Republic of India to avoid double taxation and prevent income tax evasion, the signatories agreed on the following additional provisions, which should be an integral part of this convention. Income Tax Act,1961:Communication of Section 90:Convention between the Government of the Republic of India and the Government of the Italian Republic to avoid double taxation and the prevention of tax evasion with regard to income taxes 5. In this article, "taxation" refers to the taxes that are the subject of this agreement. (a) that, in reference to Article 7, paragraph 3, the terms "expenses related to the activity of the stable establishment" are considered admissible expenses directly related to the activity of the stable establishment as well as royalties, commissions and interest corresponding to the actual amount of expenses reimbursed and, in both cases, according to the provisions of the tax legislation of the contracting state where the institution is headquartered; In the case of double taxation of the same income (between Italy and a foreign country), the person can claim foreign tax breaks for taxes paid abroad.
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