In this case, the company was founded in Japan. It formed a consortium with four other companies and entered into an agreement with an Indian company, Petronet LNG Ltd, for the construction of a liquefied natural gas and degassing plant in Gujarat. Each member of the consortium should receive separate payments. The contract included offshore procurement, offshore services, land supply, onshore services, construction and construction. The price was due for deliveries and offshore services in U.S. dollars, while the price of onshore supply as well as services, construction and assembly were partly in dollars and rupees. The third protocol also contains provisions to reduce economic double taxation in the event of transfer pricing. This is a fiscally favourable measure in line with India`s commitments under the BePS (Base Erosion and Profit Shifting) action plan to meet the minimum standard of access to the mutual agreement procedure (MAP) for transfer pricing. The third protocol also allows for the application of national legislation and measures to prevent tax evasion or evasion. Singapore`s investments of $5.98 billion pushed Mauritius as the largest individual investor for 2013/2014 with $4.85 billion.
[16] This exemption is granted by the country of origin of the tax paid by the company of origin, even if there is no mutual agreement between the two countries. Although DBAas are mapped to ease tax issues and promote investment, there may be some side effects that may arise from such agreements. “double taxation” under tax treaties generally means double legal taxation (circumstances in which a taxpayer is taxed on the same income in more than one country). There is another type of double taxation – economic double taxation. This relates to the imposition of two or more taxes on a tax basis. Second, the United States authorizes a foreign tax credit that allows for the impact of income tax paid abroad on U.S. income tax debt due to foreign income that is not covered by that exclusion. The foreign tax credit is not allowed for the tax paid on activity income, which is excluded by the rules described above (i.e. not a double immersion).
[17] In order to reduce these abuses, countries include in their agreement a clause called the Limitation of Benefits (LOB clause) that defines investments that are made solely to benefit from an agreement on double tax evasion (DBAA) or what are the real investments. In the language of the layman, a treaty is a formal agreement between two or more independent nations. The Oxford Companion to Law defines a treaty as “an international agreement, normally in writing, concluded under different titles (treaty, convention, protocol, alliance, Charter, Covenant, Statute, Law, Declaration, Declaration, Concordat, Exchange of Notes, Agreed Protocol, Memorandum of Understanding) between two or more states concluded under international law to create rights and obligations between them and be subject to international law. Examples of contracts are the CTBT, the Vienna Conventions and tax treaties such as the DBAA, etc. Under the 2013 Finance Act, a person is not entitled to relief under the Double Taxation Avoidance Agreement unless he or she provides a tax residence certificate to the sender.
