A. In India, where a resident based in India receives income that can be taxed in South Africa in accordance with the provisions of this agreement, India authorizes, as a deduction of that resident`s income tax, an amount equivalent to the South African tax paid, directly or by deduction. However, this deduction must not exceed the portion of income tax (calculated before deduction) that is attributable to income that can be taxed in South Africa. j. the term „person“ refers to a person, a corporation and any other entity of persons treated as a tax entity under the tax legislation in force in the relevant contracting states; and three. The term „dividends“ used in this article refers to income from shares or other shares of profits (non-receivables) as well as income from other rights of corporations subject to the same tax treatment as share income, in accordance with the laws of the State party where the company is based. 3. Notwithstanding paragraph 1, the income of an artist or athlete is exempt from his or her personal activity as such in the contracting state in which these activities are carried out, when the activities are carried out in the context of a visit carried out in whole or in part by another contracting state, the political division, a territorial authority or a public body. We can provide current and historical tax rates, comparison tables and country surveys through our specialized tax databases. We have current key summaries and detailed analysis of the tax system in countries around the world on corporate taxation, individual taxation, business and investment. 3.
In determining the profits of a stable establishment, seke costs incurred for the purposes of the establishment, including administrative expenses, set in the contracting state where the stable establishment is located or in another place, are allowed as a deduction, in accordance with the limits set by the tax laws of that contracting state. 2. The competent authority endeavours to resolve the matter by mutual agreement with the competent authority of the other State party, by mutual agreement, where the objection appears to be well founded and is not in a position to find a satisfactory solution to resolve the matter in agreement with the competent authority of the other contracting State, in order to avoid tax evasion which is not in accordance with the agreement. Any agreement reached will be implemented in the domestic law of the States Parties, regardless of the time frame. The agreements between the two tax administrations in two countries are intended to allow administrations to eliminate double taxation. (a) the term „India“ refers to the territory of the Republic of India and includes the high seas and airspace above it. For the purposes of this agreement, the deadline applies to all other maritime areas in which the Republic of India has, in accordance with Indian law and in accordance with international law, in particular in the 1982 United Nations Convention on the Law of the Sea, sovereignty rights, other rights and jurisdiction; And one. Notwithstanding Articles 7, 14 and 15, the income that a State party exercises as an artist, such as a theatre, film, radio or television artist or musician or sportsman from his personal activities in that other contracting state, may be taxed in that other state.