The Government of the Republic of India signed a Double Taxation Avoidance
Agreement (DTAA) with the United Republic of Tanzania for the avoidance of double
taxation and for the prevention of fiscal evasion with respect to taxes on income on 27
th
May,
2011 at Dar es Salaam. The Agreement was signed by Mr K V Bhagirath, High
Commissioner of India on behalf of the Government of India and by Mr Pereira Ame Silima,
Deputy Minister of Finance on behalf of the United Republic of Tanzania in the presence of
the Prime Minister, Dr Manmohan Singh and the President of Tanzania Mr Kikwete.
The DTAA provides that business profits will be taxable in the source state if the
activities of an enterprise constitute a permanent establishment in the source state. Examples
of permanent establishment include a branch, factory, etc. Profits of a construction, assembly
or installation projects will be taxed in the state of source if the project continues in that state
for more than 270 days.
Profits derived by an enterprise from the operation of ships or aircrafts in
international traffic shall be taxable in the country of residence of the enterprise. Dividends,
interest and royalties income will be taxed both in the country of residence and in the country
of source. However, the maximum rate of tax to be charged in the country of source will not
exceed a two-tier 5% or 10% in the case of dividends and 10% in the case of interest and
royalties. Capital gains from the scale of shares will be taxable in the country of source.
The Agreement further incorporates provisions for effective exchange of information
and assistance in collection of taxes between tax authorities of the two countries in line with
internationally accepted standards including exchange of banking information and
incorporates anti-abuse provisions to ensure that the benefits of the Agreement are availed of
by the genuine residents of the two countries.
The Agreement will provide tax stability to the residents of India and Tanzania and
facilitate mutual economic cooperation as well as stimulate the flow of investment,
technology and services between India and Tanzania
The Government of the Republic of India signed a Double Taxation Avoidance
Agreement (DTAA) with the Federal Democratic Republic of Ethiopia for the avoidance of
double taxation and for the prevention of fiscal evasion with respect to taxes on income on
25
th
May, 2011 at Addis Ababa. The Agreement was signed by Shri S.M. Krishna, External
Affairs Minister on behalf of the Government of India and by Mr. Sufian Ahmed, Minister of
Finance and Economic Development on behalf of the Federal Democratic Republic of
Ethiopia in the presence of the Prime Minister, Dr. Manmohan Singh and the Ethiopian
Prime Minister. Mr. Meles Zenawi.
The DTAA provides that business profits will be taxable in the source state if the
activities of an enterprise constitute a permanent establishment in the source state. Examples
of permanent establishment include a branch, factory, etc. Profits of a construction, assembly
or installation projects will be taxed in the state of source if the project continues in that state
for more than 183 days.
Profits derived by an enterprise from the operation of ships or aircrafts in
international traffic shall be taxable in the country of residence of the enterprise. Dividends,
interest, royalties and fees for technical services income will be taxed both in the country of
residence and in the country of source. However, the maximum rate of tax to be charged in
the country of source will not exceed 7.5% in the case of dividends and 10% in the case of
interest, royalties and fees for technical services. Capital gains from the scale of shares will
be taxable in the country of source.
The Agreement further incorporates provisions for effective exchange of information
and assistance in collection of taxes between tax authorities of the two countries in line with
internationally accepted standards including exchange of banking information and
incorporates anti-abuse provisions to ensure that the benefits of the Agreement are availed of
by the genuine residents of the two countries.
The Agreement will provide tax stability to the residents of India and Ethiopia and
facilitate mutual economic cooperation as well as stimulate the flow of investment,
technology and services between India and Ethiopia.
Tags- dtaa,double taxation aviodance agreement
