5. A business in a contracting state is not considered a stable institution in the other contracting state solely because it acts in that other state through a broker, commissioner general or other agent with an independent function, provided that they act properly. However, if the activities of such a representative are entirely or almost intended for that undertaking and the transactions between the representative and the company are not carried out under conditions of arms length, he is not considered an independent representative within the meaning of this paragraph. Cyprus has 45 double taxation agreements and is negotiating with many other countries. Under these agreements, a credit is normally accepted against the tax collected by the country in which the taxpayer is established for taxes collected in the other contracting country, resulting in the taxpayer not paying more than the higher of the two rates. Some contracts provide for an additional tax credit that would otherwise have been due had it not been provided for incentives in the other country, which would have resulted in an exemption or tax reduction. The Government of the United States of America and the Government of the Republic of India, which wish to reach an agreement to avoid double taxation and prevent tax evasion with respect to income taxes, have agreed that the United States allows its residents to credit U.S. tax in relation to: India has entered into a comprehensive agreement on the prevention of double taxation with 88 countries , 85 of which came into force.  This means that there are agreed tax rates and skill rates for certain types of income generated in one country for a country of taxation established in another country. Under India`s Income Tax Act of 1961, there are two provisions, Section 90 and Section 91, that provide taxpayers with special facilities to protect them from double taxation.
Section 90 (bilateral facilitation) applies to tax payers who have paid tax to a country with which India has signed agreements to avoid double taxation, while Section 91 (unilateral relief) provides benefits to taxpayers who have paid taxes in a country with which India has not signed an agreement. Thus, India reduces both types of taxpayers. Prices vary from country to country. B. For the purposes of this article, it is considered that the profits of a business that are in fact related to the operation of a business or business activity in the United States (or are considered to be of an effective connection) are either attributable to a stable establishment in the United States, taxable in the United States under Article 6 (Real Estate Income), Section 12 (including fees and fees for services) as royalties for inclusive services, or Section 13 of convention.