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Application of Avoidance of Double Taxation Agreement in Case of Global  ican Depository Receipts

During the period of fiduciary ownership of shares in the hands of the ODB, the provisions of  Avoidance of Double Taxation Agreement,  entered into by the Government of India with the  country of residence of the ODB, would he applicable in the matter of taxation of income  from  dividends from underlying shares and interest on FCCBs, During the period, if any, when the ~  redeemed underlying shares are held  y the non-resident investor on tr.nsfer from the fiduciary  ownership of the ODB, before they are sold to resident purchasers, the  avoidance   f Double  Taxation Agreement entered into by the Government of India with the country of residence of the non-resident investor would be   applicable in the matter of taxation of income from the dividends  of the said underlying shares, or interest on FCCBs, or any capital gain  rising out of transfer. of  underlying shares,

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