4. The competent authorities of the contracting states may communicate directly with each other in order to reach an agreement in accordance with the preceding paragraphs. The relevant authorities are developing appropriate bilateral procedures, conditions, methods and techniques for the implementation of the mutual agreement procedure under this article through consultations. At the time of the signing of today`s agreement between the Government of the Republic of India and the Government of the Republic of Indonesia to avoid double taxation and prevent income tax evasion, the signatories agreed on the following provisions, which should be an integral part of the agreement. 3. The competent authorities of the contracting states try to resolve by mutual agreement any difficulty or doubt about the interpretation or application of the convention. They can also agree on the elimination of double taxation in cases under the convention. The agreement between the Government of the Russian Federation and the Government of the Republic of Albania to avoid double taxation on income and capital taxes does not, in this agreement, affect the tax privileges of members of diplomatic or consular missions, in accordance with the general rules of international law or the provisions of specific agreements. India has signed double tax evasion agreements (DBAA) with the majority of countries and limited agreements with eight countries.
The treaties provide for income that would be taxable in one of the contracting states, based on the understanding of the nations, the conditions of taxation and the exemption from tax. (5) It is considered that in the event of a conflict in the application between the provisions of this agreement and the provisions relating to distribution contracts relating to the extraction and production of oil and gas in a contracting state concluded by the government or by a person authorized by the government, this priority is given. (d) If, under points (a) to c), its residence status cannot be determined in that order, the competent authorities of the contracting states endeavour to clarify the matter by mutual agreement. Two of them. If a contracting state takes advantage of the profits of a state-owned enterprise in the profits of a state-owned enterprise – and imposes it accordingly – the profits would have been acquired from the company of the first state if the intermediate conditions between the two enterprises had been established between independent enterprises that would have been made between independent enterprises and the profits that would have been generated by the first state company if the conditions between the two companies had been independent companies, the other state is making an appropriate correction of the amount of tax on these profits. In determining this correction, the other provisions of the Convention should be given due consideration and, if necessary, the competent authorities of the contracting states consult each other.