3. Paragraph 1 shall not apply to income received by income established in one of the Contracting States, where such income is actually linked to a permanent establishment or a fixed base in the other Contracting State. In that case, Articles 7 and 14 shall apply respectively. 2. If, pursuant to paragraph 1 of this article, a natural person resides in both States Parties, the status of that person shall be determined in accordance with the following rules: for the purposes of this paragraph, the nationality of a person of a Contracting State and the habitual residence of that person shall determine the degree of personal and economic relations of the person with that State.”; AGREEMENT FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF TAX EVASION WITH AFGHANISTAN While the Government of India and the Government of Afghanistan entered into an agreement, the applicant claimed that most of the services related to the work entrusted to it were provided in India and that, in fact, nearly 90-95% of the contract-related work in India was provided. In addition, members of the applicant`s staff were also present in India for a significant period during the financial year. . . .
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