What are advance rulings of interpretation contained in DTAA

Advance Ruling in respect of interpretation of terms contained in DTA Agreement.

The Indian income-tax contains a special provision which offers facility to those Non-residents who would like to have advance ruling on a matter of law or fact in relation to a transaction undertaken / proposed to be undertaken by them. The facilities available in such provision can be availed of by the Non-residents in the matters regarding Double Taxation of income also. More on this matter has been discussed in a separate chapter on the subject.

Persons involved in international transactions are advised to clearly understand the provisions of relevant DTAA and structure the proposed investment / transaction after careful understanding and appreciation of the domestic law provisions read with the treaty provisions so as to ensure that the expected return from the transaction is not adversely affected by unknown provision and the eventual bottom line of foreign transaction is maximised to the extent possible