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Double Taxation Avoidance Agreement Between India And Poland

1. States Parties shall provide assistance to each other in the collection of tax claims. This aid shall not be limited by Articles 1 and 2. The competent authorities of the States Parties may, by mutual agreement, regulate the application of this article. 4. Notwithstanding the income received by an enterprise of one State Party from the operation of ships from the ports of the other State Party to the ports of third countries and ports of third countries and ports of third countries and ports of third countries to ports of the other Contracting State, the State may be taxed in the other Contracting State, notwithstanding the provisions of paragraphs 1 and VIII of the Agreement of 27 June 1960 between the Government of India and the Government of the Polish People`s Republic on Maritime Cooperation; But the tax levied in that other Contracting State shall be reduced by an amount of 50%. “2. The taxation of a permanent establishment which an enterprise of a Contracting State has in the other Contracting State shall be no less advantageous in that other State than the taxation of enterprises of that other State which carry on the same activities in the same circumstances or under the same conditions. This provision should not be interpreted as preventing a State Party from calculating the profits of a company of the other State Party in the first Member State, at a higher rate of tax than that levied on the profits of a similar company of the first-mentioned Contracting State, even in contradiction with paragraph 3 of Article 7. However, the difference in tax rate must not exceed 10 percentage points. » 1. In the other State Party, nationals of a State Party may not be subject to any other taxation or obligation associated with it, which is not or is more onerous than the imposition, or to the related requirements to which nationals of that other State are or may be subject in the same circumstances and under the same conditions.

[This Agreement] shall not affect the taxation of its residents by a [Contracting State], except in respect of benefits granted in accordance with Article 9(2), Article 17(2) or Articles 18, 19, 20, 22, 24, 25 or 27 of [this Agreement]. 4. The competent authorities of the Contracting States may communicate directly with each other with a view to reaching an agreement within the meaning of the preceding paragraphs. The competent authorities shall develop, through consultations, appropriate bilateral procedures, conditions, methods and techniques for the implementation of the mutual agreement procedure provided for in this Article. . . .

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