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Exchange of Notes between Canada and India constituting an Agreement for the Avoidance of Double Taxation of Income derived from the Operation of Aircraft [1982] CATSer 17 (20 July 1982)

E102273 - CTS 1982 No. 9

EXCHANGE OF NOTES BETWEEN CANADA AND INDIA CONSTITUTING AN AGREEMENT FOR THE AVOIDANCE OF DOUBLE TAXATION OF INCOME DERIVED FROM THE OPERATION OF AIRCRAFT

I

The Secretary to the Government of India, Ministry of Tourism and Civil Aviation to the High Commissioner of Canada

New Delhi, July 20, 1982

His Excellency Mr. John G. Hadwen
High Commissioner of Canada
New Delhi.

Excellency,

I have the honour to refer to the Agreement between the Government of India and the Government of Canada signed today relating to Air Services and the agreed minutes of understanding signed at Ottawa on the 26th day of February, 1982 by the representatives of both the Governments. It was agreed that pending the entry into force of the Agreement between the Government of India and the Government of Canada for the Avoidance of Double Taxation and Prevention of Fiscal Evasion with respect to Taxes on Income, neither contracting party would levy any income tax on the income or profits derived by a designated airline of the other contracting party from the operation of aircraft.

2. I have further the honour to propose that the present letter and your Excellency's letter in reply confirming the foregoing arrangements on behalf of the Government of Canada shall be regarded as constituting an agreement the two Govern­ments, which will enter into force on the date of your Excellency's reply.

3. I avail myself of this opportunity to renew to your Excellency the assurances of my highest consideration.

B. Venkataraman

Secretary of the Ministry
of Tourism and Civil Aviation

II

The High Commissioner of Canada to the Secretary of the Government of India, Tourism and Civil Aviation

New Delhi, July 20, 1982

His Excellency Dr. B. Venkataraman
Secretary to the Government of India
Ministry of Tourism and Civil Aviation
New Delhi

Excellency,

I have the honour to acknowledge the receipt of your Excellency's letter of today's date which reads as follows:

"(See note from the Secretary of he Ministry of Tourism of July 20, 1982)"

2. I have the honour to confirm on behalf of the Government of Canada the foregoing arrangements and to agree that your Excellency's letter and this letter shall be regarded as constituting an agreement between the two Governments which will enter into force on the date of this reply.

3. I avail myself of this opportunity to renew to your Excellency the assurances of my highest condsideration.

John G. Hadwen

High Commissioner