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TMI BlogNecessary for implementing the aforesaid Convention between India and FranceX X X X Extracts X X X X X X X X Extracts X X X X ..... vernment, in exercise] of the powers conferred by section 90 of the Income-tax Act, 1961 (43 of 1961), section 24A of the Companies (Profits) Surtax Act, 1964 (7 of 1969) and section 44A of the Wealth-tax Act, 1957 (27 of 1957), had directed that all the provisions of the said Convention annexed to the notification of the Government of India in the Ministry of Finance (Department of Revenue) (Foreign Tax3[Division]) No. G.S.R. 681(E), dated 7th September, 1994, shall be given 4[effect to in] in the Union of India. And whereas paragraph 7 of the Protocol dated 29th September, 1992, to the aforesaid Convention provides that if after 1st day of September, 1989, under any 5[Convention,] Agreement or Protocol concluded between India and a third ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the Convention notified by the said notification which are necessary for implementing the aforesaid Convention between India and France, namely :-- I. With effect from 1st April, 1997, for the existing paragraph 2 of article 11 relating to "Dividends", the following paragraph shall be 8[read:] "2. However, such dividends may also be taxed in the Contracting State of which the company paying the dividends is a resident and according to the laws of that Contracting State, but if the recipient is the beneficial owner of the dividends, the tax so charged shall not exceed 10 per cent. of the gross amount of the 9[dividends."] II. With effect from 1st April, 1995, for the existing paragraph 2 of article 12 relating to &quo ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... cting State in which they arise and according to the laws of that 18[Contracting State,] but if the recipient is the beneficial owner of these categories of income, the tax so charged shall not 19[exceed:] (a) in the case of royalties and fees 20 per cent. of the gross amount of such royalties or fees ; and (b) in the case of payments referred to in paragraph 5 of this article, 10 per cent. of the gross amount of such 20[payments."] V. With effect from 1st April, 1997, for paragraph 2 of article 13 relating to "Royalties and fees for technical services and payments for the use of equipment", referred to in paragraph IV above, the following paragraph shall be 21[read:] "2. However, such 22[royalties, fees and payme ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... as "cases"." 13. Corrected vide NOTIFICATION NO. 11469 DATED 30-8-2000 before it was read as "'Interest'," 14. Corrected vide NOTIFICATION NO. 11469 DATED 30-8-2000 before it was read as "read," 15. Corrected vide NOTIFICATION NO. 11469 DATED 30-8-2000 before it was read as "interest"." 16. Corrected vide NOTIFICATION NO. 11469 DATED 30-8-2000 before it was read as "read;" 17. Corrected vide NOTIFICATION NO. 11469 DATED 30-8-2000 before it was read as "royalties and fees payments" 18. Corrected vide NOTIFICATION NO. 11469 DATED 30-8-2000 before it was read as "Contracting State" 19. Corrected vide NOTIFICATION NO. 11469 DATED 30-8-2000 before it was read as "exceed;". 20. Corrected vide NOTIFICATION NO. 11469 DATED 3 ..... X X X X Extracts X X X X X X X X Extracts X X X X
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