In January 2018, a DBA was signed between the Czech Republic and Korea.  The treaty creates double taxation between these two countries. In this case, a Korean resident (person or company) who receives dividends from a Czech company must compensate czech tax on dividends, but also Czech tax on profits, profits of the company that distributes the dividends. The contract is for the taxation of dividends and interest. Under this contract, dividends paid to the other party are taxed at a maximum of 5% of the total dividend amount for corporations and individuals. This contract reduces the tax limit on interest paid from 10% to 5%. Copyright in literature, works of art, etc., remain tax-exempt. For patents or trademarks, a maximum tax rate of 10%.  The Double Tax Evasion Agreement (DBAA) is essentially a bilateral agreement between two countries. The main objective was to promote and promote economic exchanges and investment between two countries by avoiding double taxation. Well, if country A company directs its investment in country B via country C, it will pay taxes of 0% on earned income because country C is tax-exempt by the agreement between country B and country C. The agreement on the prevention of double taxation between India and Singapore currently provides for a tax based on the residence of the capital gains of a company`s shares.
The third protocol amends the agreement effective April 1, 2017, which provides for a tax at the source of capital gains from the transfer of shares of a company. This will reduce revenue losses, avoid double non-taxation and streamline investment flows. In order to ensure the safety of investors, equity investments made before April 1, 2017 were processed in accordance with the benefit limitation clause provided by the 2005 Protocol, in accordance with the terms of the benefit limitation clause. In addition, a two-year transitional period was provided between April 1, 2017 and March 31, 2019, during which capital gains on shares in the source country are taxed at half the normal rate, subject to compliance with the terms of the benefit limitation clause. 7. Application of the provisions on the elimination of double taxation: each of the material items must be taken into account with Article 23, which defines the methods for eliminating double taxation. 6. Avoid double taxation of income by dividing tax legislation between the country of origin in which the income is generated and the recipient`s country of residence; promoting cooperation between states or between states in fulfilling their obligations and ensuring the stability of the tax burden.
In this case, the company was founded in Japan. It formed a consortium with four other companies and entered into an agreement with an Indian company, Petronet LNG Ltd, for the construction of a liquefied natural gas and degassing plant in Gujarat. Each member of the consortium should receive separate payments. The contract included offshore procurement, offshore services, land supply, onshore services, construction and construction. The price was due for deliveries and offshore services in U.S. dollars, while the price of onshore supply as well as services, construction and assembly were partly in dollars and rupees.