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(b) in the case of an application under paragraph 4, the first State immediately informs, in order to guarantee its collection, that the competent authority of the first state promptly informs the competent authority of the other state and that, at the choice of the other state, the first state suspends or withdraws its application. India is the world`s leading sourcing destination and has a market share of approximately 55% of the world`s service offering of between $185 billion and $190 billion in 2017/2018. India`s IT and iTeS industry grew in 2018/2019 to $181 billion. Industry exports increased to $137 billion in the GJ19, with experts estimating that next year, services exports could, for the first time, outpace exports of goods. In the first four months of this fiscal year, services exports brought in $74.05 billion. b. with respect to that undertaking, the agent would have a stable establishment in that other contracting state in accordance with the principles set out in Article 5, the undertaking carried out by the agent is considered to be an activity carried out in that other contracting state by that resident through a stable establishment established in that Member State, and this share of the company`s profits is attributed to that establishment. In order to eliminate double taxation with respect to the taxes covered by the agreement, without creating opportunities for non-taxation or reduced taxation by tax evasion or evasion (including through contractual shopping agreements to obtain facilities provided in the agreement for the indirect benefit of residents of third jurisdictions), no benefit will be granted, under the agreement, to an income item, if it is reasonable to obtain a conclusion. , in light of all relevant facts and circumstances, that the granting of this benefit was one of the main purposes of an agreement or transaction which, directly or indirectly, gave rise to that benefit, unless it is established that the granting of that benefit is, in these circumstances, consistent with the purpose and purpose of the relevant provisions of the agreement. The provisions of the agreement do not come into force on the same dates as the original provisions of the agreement. Any provision of the MLI could take effect at different times, depending on the nature of the taxes (withholding taxes or other taxes levied) and the decisions made by India and Australia in their LML positions. 1.

Profits from the operation of ships or aircraft, including interest on funds related to this transaction, from a country of a contracting state, are taxable only in that State 1. Notwithstanding the provisions of Articles 14 and 15, the income of residents of one State party, as theatre, film, radio or television artists, musicians and sportsmen, from their personal activities as such in the other contracting state, may be taxed in that other state. B. When the person has permanent housing in or in the two contracting states, the person is considered to be resident exclusively in the contracting state with which the person`s personal and economic relationships are closer (vital focus).