Double Taxation Avoidance Services in Nashik | DTAA Advisory | N D Savla & Associates
Double Taxation Avoidance · Nashik, Maharashtra

Double Taxation Avoidance — One Income, Taxed Once.

Advisory on treaty relief, residency tie-breaker rules and foreign tax credit for income that touches more than one tax jurisdiction.

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When the same income falls within the tax net of two countries, the outcome depends on which relief route applies — the tax treaty, or the domestic relief provisions — and on being able to demonstrate eligibility for it.

At N D Savla & Associates, we help individuals and businesses in Nashik determine their residential status under the tie-breaker rules, identify the correct treaty article for each income stream, and claim relief through the appropriate route under Section 90 or Section 91.

The relief itself is only half the exercise. We also assemble the residency certificate, Form 10F and supporting declarations that a claim needs to stand on when examined.

Our Double Taxation Avoidance Services

Treaty Eligibility Review

Assessment of whether a treaty applies to a given income stream and taxpayer.

Residency Tie-Breaker Analysis

Determination of treaty residence where dual residency arises under domestic law.

Relief Under Section 90 / 91

Advisory on claiming treaty relief or unilateral relief, whichever applies.

Foreign Tax Credit Computation

Computation and documentation of credit for taxes paid in the other country.

Form 10F & TRC Documentation

Preparation of Form 10F and coordination of the tax residency certificate.

Income-Wise Treaty Mapping

Mapping salary, business, dividend, interest and royalty income to the relevant articles.

Multi-Country Structuring Review

Review of arrangements spanning more than two jurisdictions for treaty interaction.

Form 67 Filing Support

Filing support for claiming foreign tax credit ahead of the return deadline.

Our Our Advisory Process

1

Income & Jurisdiction Mapping

We identify each income stream and the countries with a taxing claim over it.

2

Residency Determination

Residential status is established under domestic law and, where relevant, the treaty tie-breaker.

3

Relief Route Selection

We determine whether treaty relief or unilateral relief under Section 91 applies.

4

Credit & Documentation

Foreign tax credit is computed and the supporting evidence is compiled.

5

Filing & Form 67

The claim is reflected in the return and Form 67 is filed within the prescribed timeline.

Why It Matters

Income taxed once, not twice, on the same base
Correct treaty article identified for each income type
Residency tie-breaker resolved before the return is filed
Foreign tax credit claimed with supporting evidence
Form 10F and TRC in place ahead of filing
Form 67 filed within the prescribed window
Consistent treaty position across years
A documentation file that supports the claim on examination

Frequently Asked Questions

It arises when the same income is subject to tax in more than one country, typically because one country taxes on the basis of residence and another on the basis of source.
Relief may be claimed under an applicable tax treaty under Section 90, or under the unilateral relief provisions of Section 91 where no treaty applies, subject to the conditions prescribed.
It is a set of tests in a tax treaty used to determine a single country of residence for a person who would otherwise be resident in both contracting states under their domestic laws.
A tax residency certificate from the other country is generally required to claim treaty benefits, along with Form 10F where the certificate does not contain all prescribed particulars.
Form 67 is the form used to claim foreign tax credit in India and is generally required to be filed before furnishing the return of income for the relevant year.
Credit may be available under the domestic foreign tax credit rules in specified circumstances, subject to the conditions and evidence prescribed under those rules.

Income taxed in more than one country?

Tell us about the income and the countries involved — we'll determine the relief route and prepare the documentation.