- 6 Marks
ATAX – May 2019 – L3 – Q5b – Double Taxation Reliefs and Credits
State provisions on business profits, dividends, and director's fees under double taxation arrangements between countries.
Question
With respect to double taxation arrangements, state precisely the provisions on the following:
i. Business profits not arising through a permanent establishment. (2 Marks)
ii. Dividend derived by one company resident in one country from another company resident in another country.
iii. Directors’ fees and other similar payments derived by a resident of a country in his capacity as a director of a company which is a resident of another country.
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