In this case, the company was founded in Japan. It formed a consortium with four other companies and entered into an agreement with an Indian company, Petronet LNG Ltd, for the construction of a liquefied natural gas and degassing plant in Gujarat. Each member of the consortium should receive separate payments. The contract included offshore procurement, offshore services, land supply, onshore services, construction and construction. The price was due for deliveries and offshore services in U.S. dollars, while the price of onshore supply as well as services, construction and assembly were partly in dollars and rupees. The agreement on the prevention of double taxation between India and Singapore currently provides for a tax based on the residence of the capital gains of a company`s shares. The third protocol amends the agreement effective April 1, 2017, which provides for a tax at the source of capital gains from the transfer of shares of a company. This will reduce revenue losses, avoid double non-taxation and streamline investment flows. In order to ensure the safety of investors, equity investments made before April 1, 2017 were processed in accordance with the benefit limitation clause provided by the 2005 Protocol, in accordance with the terms of the benefit limitation clause.

In addition, a two-year transitional period was provided between April 1, 2017 and March 31, 2019, during which capital gains on shares in the source country are taxed at half the normal rate, subject to compliance with the terms of the benefit limitation clause. The Double Tax Evasion Agreement (DBAA) is essentially a bilateral agreement between two countries. The main objective was to promote and promote economic exchanges and investment between two countries by avoiding double taxation. Under the 2013 Finance Act, a person is not entitled to relief under the Double Taxation Avoidance Agreement unless he or she provides a tax residence certificate to the sender. To obtain a certificate of tax residence, an application must be made to the income tax authorities through Form 10FA (application for a residence certificate within the meaning of an agreement under sections 90 and 90A of the Income Tax Act 1961).

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