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TMI BlogProtocolX X X X Extracts X X X X X X X X Extracts X X X X ..... rticles 6, 13 and 16 With reference to paragraph 1 of Article 6 and Article 13 it is understood that income from immovable property and capital gains on alienation of immovable property respectively may be taxed in both the Contracting States. With reference to Article 16 it is understood that Directors' fees and other similar payments referred to in the said Article may be taxed in both the C ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... b) With respect to paragraph 3 it is understood that the administrative and general expenses incurred outside India will be allowed as a deduction in accordance with the provisions of section 44C of the Indian Income-tax Act, 1961, as effective on the date of the signing of this Convention. With reference to Article 10 When the company paying the dividends is a resident of India the tax on distrib ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e 16 Remuneration received by a member of the Supervisory Board of a company as per the Act on Business Associations (Act CXLIV of 1997) of Hungary will be taxed in accordance with the provisions of Article 16. With reference to Articles 20 and 21 For the purposes of these Articles, an individual shall be deemed to be a resident of a Contracting State if he is resident in that State in the fiscal ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s a permanent establishment in Hungary may be subject to tax in Hungary in addition to the tax on profits attributable to that permanent establishment. However, such additional tax may not exceed 10 per cent of the profits of the enterprise attributable to the permanent establishment after deducting therefrom the tax on profits chargeable on the profits of a company which is a national of Hungary ..... X X X X Extracts X X X X X X X X Extracts X X X X
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