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Example: If a U.S. citizen gets rental income from real estate in India, the rental income is taxable in India. Applicability under the Agreement: for example, the income from immovable property is as follows: (4) Provisions to eliminate double taxation: this is primarily Article 23. Article 25 (mutual consent) could also be classified in this category. 4. The competent authorities of the States Parties may, by mutual agreement, increase the dollar amounts referred to in paragraph 1 above to take account of economic or monetary developments. b. by any other convention between the States Parties. 3. If a company is established in both Contracting States under paragraph 1 of this Article, that company shall apply outside the scope of this Convention, except for the purposes of Article 10, paragraph 2 (dividends), Article 26 (non-discrimination), Article 27 (mutual agreement procedure), Article 28 (exchange of information and mutual assistance) and Article 30 (entry into force). The agreement between India and the Hong Kong Special Administrative Region (HKSAR) of the People`s Republic of China for the avoidance of double taxation is operational. The best way to understand the DBAA is to compare it to a partnership agreement between two people. The partnership uses the terms “the part of the first part” and the DBA, the terms used being “the other Contracting State”.
One can also replace the words “Contracting States” with the names of the countries concerned and re-read the DBAA for a better understanding. . . .