Hong Kong India Double Tax Agreement

According to the Organisation for Economic Co-operation and Development (OECD) model contract, the residency status of a person other than the individual is determined by the mutual agreement procedure (MAP), based on the place of actual management, the place of creation or incorporation and all other relevant factors. This provision follows the OECD Multilateral Instrument (MFI). In the absence of POPs, dual countries are not entitled to tax relief or exemptions within the meaning of the Treaty, unless this can be agreed by the competent authorities (CAs).