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TMI BlogRelief from Double taxationX X X X Extracts X X X X X X X X Extracts X X X X ..... of capital situated within the Republic of India, which, according to this Agreement, may be taxed in the Republic of India. The Federal Republic of Germany, however, retains the right to take into account in the determination of its rate of tax the items of income and capital so exempted. In the case of dividends exemption shall apply only to such dividends as are paid to a company (not includin ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... (a) ; (ii) interest ; (iii) royalties and fees for technical services ; (iv) income in the meaning of paragraph 4 of Article 13 ; (v) directors fees ; (vi) income of artistes and sports persons. (c) For the purpose of credit referred to in letter (ii) of sub-paragraph (b), the Indian tax shall be deemed to be 10 per cent of the gross amount of the interest, if the Indian tax is reduced to a lower ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... income the exemption shall apply even if the dividends are derived from holdings in other companies being residents of the Republic of India which carry on active operations and in which the company which last made a distribution has a holding of more than 25 per cent. Active operations are the following:- producing or selling goods or merchandise, giving technical advice or rendering engineering ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n either case shall not, however, exceed that part of the income-tax or capital tax (as computed before the deduction is given) which is attributable, as the case may be, to the income or the capital which may be taxed in the Federal Republic of Germany. 3. The laws in force in either of the Contracting States shall continue to govern the taxation of income and capital in the respective Contractin ..... X X X X Extracts X X X X X X X X Extracts X X X X
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