Thursday , August 16, 2018 |   21:29:16 IST
INTL TAXATION INTL MISC TP FDI LIBRARY VISA BIPA NRI
About Us Contact Us Instant Updates Newsletters
 
NEWS FLASH
 
DTAA - Tax Residency Certificate constitutes sufficient evidence for accepting status of residence as well as beneficial ownership when applying provisions of Tax Treaty: ITAT (See 'Breaking News') I-T - Treaty provisions, where beneficial to taxpayers, will override provisions of Section 206AA, upon failure of non-resident recipient to furnish PAN: ITAT (See 'Breaking News') TP - Companies engaged in diversified activities can be adopted as comparables provided their segmental results are available for verification: ITAT (See 'Breaking News') TP - Export incentives should be considered as part of turnover when working out gross profit margin in case of international transaction of exporting finished goods to AEs: ITAT (See 'Breaking News') TP - Where loan for which corporate guarantee is extended to foreign AE, is availed in local currency of its residence, then local interest rate is applicable for ALP purposes: ITAT (See 'Breaking News') GST - Credit conundrums - Overlooking them is no solution! (See 'Cob(Web)' in 'TIOL') TP - TPO cannot determine ALP on estimation basis by entertaining doubts regarding business expediency of payments for making disallowance u/s 37(1): ITAT (See 'Breaking News') TP - Closely linked transactions cannot be segregated for purpose of determining arm's length price: ITAT (See 'Breaking News') TP - Entities having huge brand image & substantial intangibles cannot be compared to captive service providers more so without segmental information: ITAT (See 'Breaking News') TP - Companies engaged in software products are not good comparables to captive software developers being functionally dissimilar: ITAT (See 'Breaking News')
 
TII SEARCH
 
 
   
Home >>
 

Exim Bank & LIC receive exemption from interest income pursuant to DTAA between India & Qatar
By TII News Service
Jul 19, 2018 , New Delhi

    

[TO BE PUBLISHED IN THE GAZETTE OF INDIA, EXTRAORDINARY, PART II, SECTION 3, SUB SECTION (ii)]

GOVERNMENT OF INDIA
MINISTRY OF FINANCE
DEPARTMENT OF REVENUE
CENTRAL BOARD OF DIRECT TAXES
NEW DELHI

NOTIFICATION NO

32/2018, Dated: July 17, 2018

S.O. 3468(E). - Whereas, the Agreement between the Government of the Republic of India and the Government of the State of Qatar for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income (hereinafter referred to as the "DTAA") was signed on the 7th April, 1999;

Whereas, clause (ii) of para 3 of Article 11 of DTAA provides for the mutual agreement for granting exemption from tax on interest derived and beneficially owned by governmental financial institutions/agencies;

And whereas, in accordance with clause (ii) of para 3 of Article 11 a mutual agreement has been reached on the 29th April 2018, through exchange of letter dated the 16th March, 2018 of Republic of India and duly accepted by State of Qatar vide their letter dated the 29th April,2018 and the said letters were exchanged between the Republic of India and the State of Qatar (as annexed herewith) for grant of exemption from tax on interest income, in accordance with clause (ii) of paragraph 3 of Article 11 of the India-Qatar DTAA;

Now, therefore, in exercise of the powers conferred by sub-section (1) of section 90 of the Income-tax Act, 1961 (43 of 1961), the Central Government hereby notifies that the provisions of said Mutual Agreement through exchange of letters, as annexed hereto, shall be given effect to in the Union of India with effect from 29th April, 2018.

ANNEXURE

Letter signed by the Government of the Republic of India on 16th March, 2018 Dear Mr. Ghanim Khalifa Al Attiyah

On behalf of the Government of the Republic of India, I have the honour to refer to the Agreement between the Government of the Republic of India and the Government of the State of Qatar for the avoidance of double taxation and for the prevention of fiscal evasion with respect to taxes on income (DTAA) which came into force on 15th January, 2000.

Considering the proposal on behalf of the Government of the State of Qatar and the proposal on behalf of the Government of the Republic of India, for the purposes of clause (ii) of paragraph 3 of Article 11 of the said DTAA, following governmental financial institutions/agencies are mutually agreed upon between the two Contracting States for granting tax exemption on interest income under the said Article 11(3)(ii) from the date of reaching this mutual agreement:

(a) In the case of India, the Export Import Bank of India and Life Insurance Corporation of India; and

(b) In the case of Qatar, the Qatar Investment Authority and Qatar Holding LLC.

If the foregoing proposal is acceptable to the Government of the State of Qatar, on behalf of the Government of the Republic of India, I have the honour to suggest that the present note be regarded as constituting a mutual agreement reached in terms of clause (ii) of paragraph 3 of Article 11 of the said India- Qatar DTAA between the two Governments, on the day you formally confirm its acceptance.

Regards

Yours sincerely,
(Sushil Chandra)

Letter signed by the Government of the State of Qatar on 29th April, 2018

Dear Mr. Sushil Chandra

On behalf of the Government of the State of Qatar, I have the honour to acknowledge receipt of your note dated 16th March, 2018, which reads as follows:

"On behalf of the Government of the Republic of India, I have the honour to refer to the Agreement between the Government of the Republic of India and the Government of the State of Qatar for the avoidance of double taxation and for the prevention of fiscal evasion with respect to taxes on income (DTAA) which came into force on 15th January, 2000.

Considering the proposal on behalf of the Government of the State of Qatar and the proposal on behalf of the Government of the Republic of India, for the purposes of clause (ii) of paragraph 3 of Article 11 of the said DTAA, following governmental financial institutions/agencies are mutually agreed upon between the two Contracting States for granting tax exemption on interest income under the said Article 11(3)(ii) from the date of reaching this mutual agreement:

(a) In the case of India, the Export Import Bank of India and Life Insurance Corporation of India; and

(b) In the case of Qatar, the Qatar Investment Authority and Qatar Holding LLC.

If the foregoing proposal is acceptable to the Government of the State of Qatar, on behalf of the Government of the Republic of India, I have the honour to suggest that the present note be regarded as constituting a mutual agreement reached in terms of clause (ii) of paragraph 3 of Article 11 of the said India-Qatar DTAA between the two Governments, on the day you formally confirm its acceptance."

In reply, on behalf of the Government of the State of Qatar, I have the honour to say that the Government of the State of Qatar accepts the proposal made therein and this reply shall constitute a mutual agreement reached today in terms of clause (ii) of paragraph 3 of Article 11 of the India-Qatar DTAA, between the two Governments.

[F.No.504/6/2004-FTD-II(Pt.1)]

(Ghanim Khalifa Al Attiyah)
Rajat Bansal, Jt. Secy.

 
 
INTL TAXATION INTL MISC TP FDI LIBRARY VISA BIPA NRI TII
  • DTAAs
  • TIEAs
  • Circulars
  • Circulars (I-T Act, 1922)
  • Instructions
  • Notifications
  • Administrative Orders
  • DRP Panel
  • I-T Act, 1961
  • Relevant Portion of I-T Rules,1962
  • Relevant Portion of I-T Act,1922
  • GAAR
  • Equalisation Levy
  • Draft Guidelines
  • Committee Reports
  • FATCA
  • Intl-Taxation
  • Finance Acts
  • Manual on EoI
  • DTC Bill
  • UN Model
  • Miscellaneous
  • Guidance Notes - AEOI
  • OECD Conventions
  • Cost Inflation Index
  • Union Budget
  • Information Security Guidelines
  • Draft Notifications
  • Circulars
  • Instructions
  • Notifications
  • Relevant Sections of Act
  • TP Rules
  • Forms
  • Miscellaneous
  • APA Annual Report
  • APA Rules
  • APA FAQ
  • UN Manual on TP
  • Safe Harbour Rules
  • US Transfer Pricing
  • FEMA Act
  • Exchange Manual
  • Fema Notifications
  • Master Circulars
  • Press Notes
  • Rules
  • RBI Circulars
  • FDI Circulars
  • Reports
  • FDI Approved
  • RBI Other Notifications
  • FIPB Review
  • Black Money Act
  • PMLA Notification
  • PMLA Instruction
  • PMLA Bill
  • FM Budget Speeches
  • SEBI
  • Multimodal Transportation
  • Vienna Convention
  • NBFC Reports
  • EXIM Bank LoC
  • Manufacturing Policy
  • FTDR Act, 1992
  • Intellectual Property
  • White Paper on Black Money
  • Posting Policy
  • PMLA Cases
  • Transfer of Property
  • CBR Act, 1963
  • MCA Circular
  • Book Review
  • Limitation Act
  • SSAs
  • EPFO
  • Dx666
  • Acts
  • Rules
  • Guidelines
  • Tourist Visa
  • Notifcations
  • Types of Visa
  • Agreements
  • Arbitration
  • Model Text
  • Relevant Portion of I-T Act
  • Circulars
  • I-T Rules, 1962
  • MISC
  • Notification
  • About Us
  • Contact Us
  •  
     
    A Taxindiaonline Website. Copyright © 2010-2018 Taxindiainternational.com Pvt.Ltd. All rights reserved.