THE CBDT has finally notified the India-Mexico DTAA
with effect from February 1, 2010. The agreement was arrived at way back
on September 10, 2007.
The sub-paragraph
(a) of paragraph 3 of Article 30 of the said Agreement provides that the
provisions of the Agreement shall have effect in India in respect of
the taxes withheld at source, for amounts paid or credited on or after 1st
April of the calendar year next following the year in which the Agreement
enters into force; and in respect of taxes on income, for any fiscal year
beginning on or after 1st April of the calendar year next following the year
in which the Agreement enters into force.
Along
with the DTAA, the Protocol amending certain Articles has also been notified.
One of the amendments is in relation to Article 5 which clarifies that for
the purposes of computing the time limits,
the activities carried on by an enterprise associated with another enterprise
within the meaning of Article 9 shall be aggregated with the period during
which the activities are carried on by the associated enterprise, if the
activities of both enterprises are identical or substantially similar for
the same or connected project.
See full text of Notification
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