(5) It is considered that in the event of a conflict in the application between the provisions of this agreement and the provisions relating to distribution contracts relating to the extraction and production of oil and gas in a contracting state concluded by the government or by a person authorized by the government, this priority is given. The revised tax treaty provides for an effective exchange of information, including banking data and information that has no national tax interests, official sources told the PTI. The contract also provides for tax collection assistance and includes the performance clause of s (LoB) clause and anti-abuse provisions to ensure that the benefits of the agreement are used by actual residents, sources said. The 1987 tax treaty between the two countries will no longer have an effect on the effective dates of the new treaty. 7. Because of a special relationship between the payer and the actual beneficiary or between the two and another person, the amount of interest is greater than the amount that would have been agreed by the payer and the actual beneficiary in the absence of such a relationship. the provisions of this section apply only to the amount of the last interest. In this case, the excess portion of the payments remains taxable under the legislation of each contracting state, taking due account of the other provisions of this agreement. At the time of the signing of today`s agreement between the Government of the Republic of India and the Government of the Republic of Indonesia to avoid double taxation and prevent income tax evasion, the signatories agreed on the following provisions, which should be an integral part of the agreement. 2. The competent authority endeavours to resolve the matter by mutual agreement with the competent authority of the other contracting State where the objection appears to be well founded and is unable to find a satisfactory solution to resolve the matter by mutual agreement with the competent authority of the other contracting State, in order to avoid tax evasion that is not in accordance with the agreement.
Any agreement reached will be implemented in the domestic law of the States Parties, regardless of the time frame. Capital gains were not regulated in the previous DBA agreement. It has been modified in line with the Organisation for Economic Co-operation and Development (OECD) model. The OECD model is an agreement developed by OECD countries, which focuses on guiding tax issues during bilateral negotiations. 3. When a person other than a person is established in the two contracting states under paragraph 1, he or she is considered to reside only in the state where his or her place of effective administration is located. If the State in which its head office is located cannot be determined, the competent authorities of the contracting states try to resolve the matter by mutual agreement. 1. States parties assist each other in the collection of revenue fees. This support is not limited by Articles 1 and 2. The competent authorities of the contracting states may, by mutual agreement, regulate the manner in which this article is applied.