Double Taxation Agreement With South Korea

3. The term “permanent installation” also includes a construction site, assembly or assembly project or monitoring activities related to it, but only if such a project or such activity lasts more than nine months. (2) For the purposes of paragraph 1, the concept of “Indian tax price” is considered to be an amount of pure Indian who should have been paid under Indian tax law, but for the exemption or reduction of the Indian tax under the incense stick laws to promote economic development in India, which should have been paid at the time of signing this convention or other provisions that may later be imported in India amend these laws or, moreover, to the extent that they are agreed by the competent authorities of the contracting states, provided that the amount of tax covered in this paragraph does not exceed: 2. Notwithstanding the provisions of paragraph 1 of this article, the profits derived from the operation of ships in international traffic may be taxed in the contracting state in which this transaction is carried out; but the tax thus collected must not exceed 50% of the tax normally collected by the state`s national legislation. 1. Where a resident of a contracting state considers that the actions of one or both of the contracting states result in or lead to an imposition that does not comply with the provisions of this Convention, he may, notwithstanding the remedies provided for by the national law of those States, pass his case to Article 25, paragraph 1, of the competent authority of the contracting state of which he is domiciled. , to the contracting state of which it has nationality. This case must be brought within three years of the first notification of the tax action, which is not covered by the agreement. 3. For the purposes of this article, the term “aircraft operation” includes the transportation of passengers, livestock, goods or postal parcels carried by owners or takers or writings, of aircraft, including the sale of air tickets for that transport on behalf of other companies, the accidental rental of character aircraft and any other activity directly related to these activities. transport.

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