Individuals (“individuals”) can only reside in one country. People who have foreign subsidiaries may have their headquarters in one country and reside in another country: a subsidiary may receive substantial income in one country, but transfer that income (for example. B in the form of royalties) to a holding company in another country that has a lower corporate tax rate. This is why controlling inappropriate corporate tax evasion becomes more difficult and requires more investigation when goods, rights and services are transferred. [5] It is not uncommon for a company or person established in one country to make a taxable profit (profits, profits) in another country. A person may have to pay taxes on that income on the spot and in the country where it was produced. The stated objectives for concluding a contract often include reducing double taxation, eliminating tax evasion and promoting the efficiency of cross-border trade. [2] It is generally accepted that tax treaties improve the security of taxpayers and tax authorities in their international transactions. [3] Example of the benefit of double taxation agreements: Suppose interest on NRAs [need for clarification] bank deposits remove 30 percent of tax deduction at source in India. Since India has signed agreements with several countries to avoid double taxation, the tax can only be deducted at 10-15% instead of 30%. The third protocol also contains provisions to reduce economic double taxation in the event of transfer pricing. This is a fiscally favourable measure in line with India`s commitments under the BePS (Base Erosion and Profit Shifting) action plan to meet the minimum standard of access to the mutual agreement procedure (MAP) for transfer pricing.

The third protocol also allows for the application of national legislation and measures to prevent tax evasion or evasion. Singapore`s investments of $5.98 billion pushed Mauritius as the largest individual investor for 2013/2014 with $4.85 billion. [16] The role of double taxation conventions is to control how profits are taxed in different countries. There are two types of double taxation: double taxation and double economic taxation. In the first case, where the source rule overlaps, the tax is collected by two or more countries, in accordance with their national legislation, for the same transaction, the income is born or applies in their respective jurisdictions. In the latter case, when the same transaction, the element of income or capital is taxed in two or more states, but in the hands of another person, there is double taxation. [1] A foreign company may benefit from tax exemptions in Russia if it provides relevant evidence that it is already paying taxes in the country that are part of the contracts.