(d) if he is a national of either state or one, the competent authorities of the contracting states resolve the matter by mutual agreement. 3. In determining the profits of a stable establishment, the deduction may be made for expenses related to the institution`s activity, including an adequate distribution of administrative expenses, research and development expenses, interest and other expenses incurred for the purposes of the business as a whole (or part of which includes the establishment). , whether they were created in the state where the stable settlement is located or in any other place, according to the provisions and subject to the limitations of the state`s tax law. However, such a deduction is not eligible for amounts paid by the stable institution or any of its other offices to the stable establishment or to any of its other offices through royalties, royalties or similar payments against the use of patents, know-how or other rights, or through commissions or other commissions for certain services provided or for administration. , or, except in the case of banking companies, as an interest rate on funds lent to the institution. similarly, the determination of the profits of a stable establishment does not take into account the amounts charged by the institution at the head office of the company or one of its other offices in return for the use of patents, know-how or other rights in return for the use of patents, know-how or other rights. , or through commissions or other commissions on certain services provided or for administration or, except in the case of a banking company, as interest on funds lent to the company`s headquarters or to one of its other offices. 3. The term “dividends” used in this article refers to income from shares or other rights that are not claims that participate in profits, income from other business rights that are subject to the same tax treatment under the tax laws of the state in which the distribution company is the same tax treatment as income from shares subject to the tax legislation of the State of which the distribution company is resident; and income from arrangements, including bonds, which have the right to participate in profits, to the extent that state party legislation where income is collected justifies it. Many tax havens such as Mauritius, Singapore and the United Arab Emirates (United Arab Emirates) have signed agreements to avoid double taxation and have demonstrated their commitment to facilitating the effective exchange of information for tax purposes. 3.
Notwithstanding any provision of the Convention except paragraph 4, a contracting state may tax its residents (in accordance with Article 4 (domicile) and tax its citizens on the basis of their nationality, as if the convention had not entered into force. To this end, the term “citizen” covers a former citizen whose loss of nationality was one of his main objectives: tax evasion, but only for a period of ten years after that loss. Agreement between the Government of the United States of America and the Government of the Republic of India to avoid double taxation and prevent income tax evasion 4.