7. Where profits contain elements of result that are treated separately in other sections of this agreement, the provisions of the articles are not determined by the provision of this section. 1. Notwithstanding the provisions of Articles 14 and 15, the income of public artists (such as theatre films, radio or television symbols and musicians) or sportsmen resulting from their personal activities may be taxed as such in the contracting state in which these activities are carried out. 5. Notwithstanding Article 2, the provisions of this section apply to all taxes and denominations. The Double Tax Avoidance Agreement (DBAA) is a tax agreement signed between two or more countries to help taxpayers avoid double taxes on the same income. A DTAA is applicable in cases where a person is established in one nation but earns income in another nation. The agreement between the Government of the Republic of India and the Government of the Democratic Socialist Republic of Sri Lanka to avoid double taxation and prevent tax evasion on income and capital has been ratified and ratification instruments exchanged in accordance with Article 29 of the Convention. (d) if he is a national of either state or one, the competent authorities of the contracting states resolve the matter by mutual agreement. Provided that this credit does not exceed the Indian tax (calculated before the admission of such credit) corresponding to income from sources in Sri Lanka or capital in Sri Lanka, if such a resident is a company by which a tax is to be paid in India, the credit in India, the aforementioned credit is granted at first instance against the income tax of the company in India.
, and pay the balance if from him in India. 4. The provision of paragraphs 1 and 2 of this section does not apply where the actual beneficiary of the dividends, as a resident of a contracting state, operates in the other contracting state where the company that determines the dividends is established, is established through a stable institution established there and the operation for which the dividends are paid is in fact linked to that institution. In this case, the provisions of section 7 apply. (6) Interest is taken for granted in a contracting state where the payer is itself, a territorial authority or a resident of that state. However, if the person who pays the interest, whether or not he is domiciled in a contracting state, has a stable institution in a contracting state where the interest debt is paid and the interest is borne by that institution, those interests are deemed to be those of the contracting state where the stable institution is established. 2. When a firm in a contracting state intervenes when a company in a contracting state operates in another contracting state through a stable establishment there, each contracting state is obliged to charge, in each contracting state, the profits it must make in each contracting state if it is a self-sustaining and autonomous company carrying out the same or similar activities under the same or similar conditions and under similar conditions and totally independent with the company of which it is an establishment. stable. 3.
Notwithstanding the provisions of paragraph 2 of this article, interest incurred in a contracting state is exempt in that state: a.