3. Notwithstanding the provisions of this article, the remuneration of a job on board a ship or aircraft in international traffic can only be taxed in the contracting state in which the actual management of the business is located. 2. When a firm in a contracting state intervenes when a company in a contracting state operates in another contracting state through a stable establishment there, each contracting state is obliged to charge, in each contracting state, the profits it must make in each contracting state if it is a self-sustaining and autonomous company carrying out the same or similar activities under the same or similar conditions and under similar conditions and totally independent with the company of which it is an establishment. Stable. The agreement between the Government of the Republic of India and the Government of the Democratic Socialist Republic of Sri Lanka to avoid double taxation and prevent tax evasion on income and capital has been ratified and ratification instruments exchanged in accordance with Article 29 of the Convention. 1. Income generated by a resident of a State party for professional services or other independent activities is taxable only in that state, unless his stay in the other contracting state is more than 120 days over a period or for a period of twelve months if such income can also be taxed in the other contracting state. 5. Where a corporation established in a contracting state derives profits or income from the other contracting state, that other state may not collect tax on the dividends paid by the corporation, unless those dividends are paid to a country in that other state or the shareholding for which the dividends are paid is effectively linked to a stable institution in that other state.
, and the company`s un distributed profits are not subject to a tax on un distributed profits, even if the dividends paid or the untributed profits consist, in whole or in part, of profits or income generated in another state. (d) if he is a national of either state or one, the competent authorities of the contracting states resolve the matter by mutual agreement. a. he is considered a resident of the state in which he has a permanent homeland. If he has a permanent homeland in both states, he is considered a resident of the state with which his personal and economic relationships are more closely linked (vital focus); 1. Legislation in one of the contracting states continues to govern the taxation of income and capital in the contracting states concerned, unless this convention expressly states otherwise. Where income or capital is taxed in the two contracting states, double taxation is exempt in accordance with the following paragraphs of this article. 2. Notwithstanding paragraph 1, profits from the operation of ships in international traffic may be taxed in the contracting state where this transaction is carried out, but the tax thus collected cannot exceed 50% of the tax collected by that state`s international law. “Preliminary work on the agreements will be completed shortly and the DBAA will be signed later,” the Commissioner said, adding that such agreements are essential to promoting trade and investment. Provided that this credit does not exceed the Indian tax (calculated before the admission of such credit) corresponding to income from sources in Sri Lanka or capital in Sri Lanka, if such a resident is a company by which a tax is to be paid in India, the credit in India, the aforementioned credit is granted at first instance against the income tax of the company in India. , and pay the balance if from him in India.