December 2020

Articles 8 and 24 of India-Singapore DTAA Limitation of Relief (LOR) provisions (Article 24 of India-Singapore DTAA) are not applicable if (a) India does not have right to tax income pursuant to treaty provision, (b) income is taxed in Singapore under accrual basis. Accordingly, Article 24 is not applicable to shipping income earned by Singapore tax resident which is not taxable in India as per Article 8 of DTAA as also taxable on accrual basis in Singapore

Dhishat B. Mehta | Bhaumik Goda
Chartered Accountants

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