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Tax Treaty Between
Armenia
and
India
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Download:
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Not Available
(opens in new window) |
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File Type:
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Status:
In Force
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Number of
Armenia
Treaties:
38
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See All
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Number of
India
Treaties:
23
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See All
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Introductory note on Tax Treaty Planning
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Tax Treaties (double taxation agreements or DTAs) are international agreements or
conventions concluded with the object of eliminating double taxation by the contracting
states. To succeed in international tax planning, it is essential to engage in deep
and far-reaching calculations. Tax treaties themselves and the OECD Commentary on
the Model Convention give you practical hands-on guidance on international tax planning
issues.
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Treaty Shopping under the
Armenia
–
India
Tax Treaty
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Treaty shopping is the use of a tax treaty by a person resident in a country that
is not a party to the treaty, i.e. in the present instance by someone who is a resident
of neither
Armenia
nor
India. However, it is becoming
more and more difficult to use provisions, which were intended to prevent double
taxation, in such a way that they result, for the purposes of an international tax
plan.
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Tax Treaty news from the OECD
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The OECD has released two reports submitted to its Committee on Fiscal Affairs by
an Informal Consultative Group of business and government representatives. The Reports
address, respectively:
(a) Technical issues relating to granting treaty benefits with respect to income
of collective investment vehicles; and
(b) Procedural barriers to claims for treaty benefits that affect portfolio investors
more generally.
These are issues which may impact on international tax planning transactions.
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Know your Offshore Terms:
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| | Cross-border initial public offerings (“IPOs” or listings) on offshore and foreign exchanges create the opportunity to access hitherto untapped financial markets. As a general rule, open-ended funds tend to list on offshore exchanges where the IPO requirements are less onerous than on the major exchanges. The Dublin stock exchange has gone out of its way to attract funds, as have exchanges in a number of tax havens or international offshore financial centers (IOFCs), such as Bermuda, the Cayman Islands, the Channel Islands and Luxembourg. | | | | | Transfer pricing provisions give the tax authorities the power to reallocate profits and losses where the parties are related and/or the transactions in question are not at arm’s length or for a legitimate business purpose. Transfer pricing measures may prevent the coming into operation of an international tax planning that fails to take them into account. | | | | | Tax treaties (double taxation agreements or DTAs) are international agreements or conventions concluded with the prime objective of eliminating double taxation by the contracting states. | | | | | One of the main features of high tax systems with offshore potential is the tax shelter, which is really an investment with a flow-through of tax benefits. Artificial losses may be offset not only against income from the investment out of which they arise, but also against the taxpayer’s other income, usually from his regular business or professional activity. A tax shelter may be a useful element in an international tax planning structure. | | |
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