Some investments with a flow-through or pass-through structure, such as.B. Master-Sponsors, are popular because they avoid the double taxation syndrome. Shortly after we started searching hundreds of thousands of anonymously sent files from the island state of Mauritius, we asked ourselves: what are all these “double taxation treaties” or “tax treaties” that we see again and again? So what are the advantages of such an agreement? However, this original reason for wanting to avoid double taxation has not completely disappeared, as there will always be some differences in how countries treat profits. The concept of double taxation of dividends has given rise to important debates. While some argue that the taxation of their dividends by shareholders is unfair because these funds have already been taxed at the company level, others argue that this tax structure is fair. A DBA (Double Taxation Convention) may require that the tax be levied by the country of residence and that it be exempt in the country where it is created. In other cases, the resident may pay a withholding tax to the country where the income was born and the taxpayer benefits from a compensatory foreign tax credit in the country of residence to reflect the fact that the tax has already been paid. In the first case, the taxpayer (abroad) would declare himself a non-resident. In both cases, the DBA may provide for the two tax authorities to exchange information on these returns. Through this communication between countries, they also have a better view of individuals and companies trying to avoid or evade taxes.  (For a transitional period, some States have a separate regime.[ 8] You can offer any non-resident account holder the choice of tax arrangements: either (a) disclosure of the information mentioned above, or (b) deduction at source of local tax on savings income, as is the case for residents). The Third Protocol also contains provisions facilitating the facilitation of economic double taxation in transfer pricing cases.
This is a favourable tax measure and in line with India`s commitments under the Base Erosion and Profit Shifting (BEPS) action plan to meet minimum standards for access to the Mutual Agreement Procedure (MAGP) in transfer pricing cases. The Third Protocol also allows for the application of national law and measures to prevent tax evasion or evasion. Singapore`s investment of S$5.98 billion surpassed Mauricie`s investment of $4.85 billion as the top individual investor for 2013-14.  The signing of a convention for the avoidance of double taxation has essentially four effects. . . .