(ii) the term “India,” the territory of India and includes the coastal sea and airspace, as well as any other maritime area in which India has high rights and jurisdictions under Indian law and in accordance with international law, including the United Nations Convention on the Law of the Sea; 4. To the extent that it was customary in a contracting party to determine the profits attributable to a stable establishment on the basis of a distribution of the company`s total profits between its various parties or on the basis of another method prescribed by that party`s legislation, it does not preclu her the contracting party from determining the taxable profits under that allocation or any other method; However, the method used must be consistent with the principles set out in this article. Two of them. Profits from the disposal of personal property that are part of the commercial ownership of a stable establishment that a firm of one contracting party has in the other contracting party or from personal objects relating to a fixed plate available to d a resident of a contracting party of the other party to provide independent personal services, including the benefits derived from the disposal of such an establishment (alone or with the entire company) or from such a fixed base , may be taxed in this other contracting party. 2. Under Hong Kong national law, Indian residents of Hong Kong are not subject to withholding tax on dividends, interest or FTT, while royalties are subject to a 4.95% withholding tax in Hong Kong in Hong Kong. 6. Profits from the disposal of assets other than those covered in paragraphs 1, 2, 3, 4 and 5 may be taxed in each contracting party in accordance with their domestic law. (a) a construction site, construction, assembly or assembly project or monitoring activity related to it, but only if that project, project or project lasts more than six months; 5.

Existing taxes, as well as taxes collected after the signing of the agreement, are referred to as the Hong Kong Special Administrative Region Tax or “Indian Tax,” as the context requires. However, the term “Hong Kong tax for the Hong Kong Special Administrative Region” or “Indian tax” does not include penalties or interest or fines imposed under a party`s legislation with respect to the taxes to which the agreement applies. (b) the provision of services, including consulting services, by workers or other staff recruited for this purpose by the company, but only if such activities (for the same project or related project) continue within a contracting party for a cumulative period or period of more than 183 days over a 12-month period.