Athena Wild

Many researchers have found that certain foods can lower high blood pressure. We look at some foods that may help and how to incorporate them into the diet.

In general, the United States Department of Agriculture (USDA) considers a serving to be:

For most ages, the USDA recommends consuming around 2 cups of fruit per day and 3 cups of vegetables per day, although this varies slightly according to age and sex.

Blueberries and strawberries contain antioxidant compounds called anthocyanins, a type of flavonoid.

In one older study, the researchers looked at data for over 34,000 people with hypertension over 14 years. Those with the highest intake of anthocyanins — mainly from blueberries and strawberries — had an 8% lower risk of high blood pressure than those with a low anthocyanin intake.

However, some experts say there is not enough evidence that blueberries reduce blood pressure.

To enjoy berries:

A serving of blueberries is around 1 cup of fresh or frozen blueberries or half a cup of dried blueberries. A serving of strawberries is around 7 strawberries.

Which other foods are rich in antioxidants?

Bananas contain potassium, which can help manage hypertension. One medium-sized banana contains around 422 milligrams (mg) of potassium.

According to the American Heart Association (AHA), potassium reduces the effects of sodium and alleviates tension in the walls of the blood vessels.

The Office of Dietary Supplements advises that males aim to consume 3,400 mg of potassium daily and females — 2,600 mg.

Other potassium-rich foods include:

People with kidney disease should consult a doctor before increasing their intake of potassium, as too much can be harmful.

A serving would be 1 large banana, 1 cup of sliced banana, or two-thirds of a cup of mashed banana.

Drinking beet juice may reduce blood pressure in the short and long term, because it contains dietary nitrate.

A 2015 study found that people with hypertension who drank 250 milliliters (ml), or about 1 cup, of red beet juice every day for 4 weeks had lower blood pressure. The researchers recorded an average fall in blood pressure of 7.7/5.2 millimeters of mercury (mm Hg) over a 24-hour period.

Tips for use include:

A serving of beet is around 1 cup, which is around 2 small beets or 1 large one.

Cacao, an ingredient in dark chocolate, contains flavonoids, an antioxidant. Flavonoids may help reduce blood pressure, according to the AHA.

However, it notes that a person may not be able to consume enough flavonoids in dark chocolate for it to have significant benefits.

The AHA says that a small amount of chocolate from time to time can be part of a balanced diet. It advises, however, that people eat it because they enjoy it, not for health reasons.

A daily serving of kiwi can help manage mildly high blood pressure, a 2015 study suggests.

People who ate 3 kiwis per day for 8 weeks saw a more significant reduction in systolic and diastolic blood pressure than those who ate 1 apple per day for the same period. The study authors note that this may be due to the bioactive substances in kiwis.

Kiwis are also rich in vitamin C. In an older study, people who consumed around 500 mg of vitamin C per day for about 8 weeks saw significant improvements in their blood pressure readings.

Kiwis are easy to add to lunches or smoothies. One cup of kiwi, or 2–3 kiwifruits, makes up 1 serving.

Which other foods contain vitamin C?

Watermelon contains an amino acid called citrulline.

The body converts citrulline to arginine, and this helps the body produce nitric oxide, a gas that relaxes blood vessels and encourages flexibility in arteries. These effects aid the flow of blood, which can lower high blood pressure.

In one older study, adults with obesity and mild or prehypertension took watermelon extract containing 6 grams (g) of L-citrulline/L-arginine.

After 6 weeks, the participants saw a reduction in blood pressure in the ankles and brachial arteries. The brachial artery is the main artery in the upper arm.

In a small 2019 study, 27 people consumed either watermelon juice or another drink before exercise. The females who drank watermelon juice did not experience a rise in blood pressure after exercise, although the males did.

People can consume watermelon:

One serving of watermelon is 1 cup of chopped fruit or 1 slice of around 2 inches.

Oats contain a type of fiber called beta-glucan, which may have benefits for heart health, including blood pressure.

A 2020 rodent study found that beta-glucan and avenanthramide C, both present in oats, reduce levels of malondialdehyde, a marker of oxidative stress in hypertensive rats. These results suggest that ingredients present in oats can help prevent high blood pressure and protect heart health in other ways.

Ways of eating oats include:

Leafy green vegetables are rich in nitrates, which help manage blood pressure.

Some research suggests that eating at least 1 cup of green leafy vegetables per day can lower blood pressure and reduce the risk of cardiovascular disease.

Examples of leafy greens include:

To consume a daily dose of green vegetables, a person can:

A serving of spinach is 2 cups of fresh leaves. A serving of raw cabbage is 1 cup.

Garlic has antibiotic and antifungal properties, many of which may be due to its main active ingredient, allicin.

A 2020 review concludes that garlic in general, and specifically Kyolic garlic, can reduce:

Garlic can enhance the flavor of many savory meals, including stir-fries, soups, and omelets. It can also be an alternative to salt as a flavoring.

Fermented foods are rich in probiotics, which are beneficial bacteria that may help manage blood pressure.

In 2020, researchers analyzed data for 11,566 adults aged 50 years or older in Korea. The results suggest that women who had gone through menopause and ate fermented soy foods had a lower risk of hypertension. However, this did not appear to be true for men.

Sodium is a risk factor for high blood pressure, and experts advise people to limit their salt intake. However, a 2017 study did not find that eating salt-fermented vegetables increased the risk of high blood pressure, despite the high sodium content.

The effects of probiotics on blood pressure appeared more beneficial when the participants consumed:

Fermented foods to add to the diet include:

Probiotic supplements are another option.

Lentils provide protein and fiber, and experts say they can benefit the blood vessels of people with hypertension.

The authors of an older study analyzed the effects of a pulse-rich diet on rats. The rats consumed a diet that was 30% pulses, including beans, peas, lentils, and chickpeas. Consuming pulses appeared to decrease levels of blood pressure and cholesterol.

A 2014 review of human trials, with a total of 554 participants, found that consuming pulses may lower blood pressure in people with and without hypertension. However, the authors note that more studies are necessary.

People can use lentils in many ways, including:

Yogurt is fermented dairy food.

A 2021 study looked at data for people with and without high blood pressure to see whether there was a link between fermented dairy products and hypertension.

The participants with high blood pressure who consumed more yogurt had lower systolic blood pressure and lower arterial pressure than those who did not.

To enjoy unsweetened yogurt:

Pomegranates contain antioxidants and other ingredients that may help prevent high blood pressure and atherosclerosis.

An older study from 2012 provides evidence that drinking 1 cup of pomegranate juice daily for 28 days may lower high blood pressure in the short term.

A 2017 review of eight human trials found evidence that consuming pomegranate juice consistently lowered blood pressure.

People can consume pomegranates whole or as juice. When buying prepackaged pomegranate juice, check to ensure that there is no added sugar.

Cinnamon may help reduce blood pressure, according to a 2020 review. The authors found that consuming up to 2 g of cinnamon per day for 8 weeks or more reduced blood pressure in people with a body mass index of 30 or more.

To incorporate cinnamon into the diet, a person can:

Several studies have found that eating nuts of various types can help manage hypertension.

A 2016 review notes that walnuts, hazelnuts, and pistachios all appear to improve endothelial function, which can benefit blood pressure and heart health.

Opt for unsalted nuts and:

People should not consume nuts if they have a nut allergy.

Citrus fruits contain hesperidin, an antioxidant that may benefit heart health.

In a 2021 study, 159 people consumed 500 ml of orange juice, hesperidin-enriched orange juice, or a control drink per day for 12 weeks.

The results indicate that regularly consuming orange juice can help lower systolic blood pressure and that hesperidin contributes to this effect.

People can consume citrus fruits:

The AHA recommends consuming 2 servings of 3 ounces (oz) of oily fish per week, as it may lower the risk of cardiovascular disease.

Research also suggests that eating oily fish may help lower blood pressure. In 2016, people with high systolic blood pressure saw significant improvements in their readings after consuming 0.7 g per day of supplements of eicosapentaenoic acid and docosahexaenoic acid fish oil for 8 weeks.

Examples of oily fish are:

Some fish contain mercury, and people should check the latest Food and Drug Administration (FDA) guidelines. They can also visit this website to check which fish is currently sustainable.

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Bone density scanning, also called dual-energy x-ray absorptiometry (DXA) or bone densitometry, is an enhanced form of x-ray technology that is used to measure bone loss. DXA is today's established standard for measuring bone mineral density (BMD).

Meaning of Treaty:

In layman’s language, a treaty is a formally concluded agreement between two or more independent nations. The Oxford Companion to Law defines a treaty as “an international agreement, normally in written form, passing under various titles (treaty, convention, protocol, covenant, charter, pact, statute, act, declaration, concordat, exchange of notes, agreed minute, memorandum of agreement) concluded between two or more states, on subject of international law intended to create rights and obligations between them and governed by international law. Examples of treaty include CTBT, Vienna Convention, and Tax Treaty such as DTAA etc.

The Double Tax Avoidance Agreement (DTAA)

The Double Tax Avoidance Agreement (DTAA) is essentially a bilateral agreement entered into between two countries. The basic objective is to promote and foster economic trade and investment between two Countries by avoiding double taxation.

International double taxation has adverse effects on the trade and services and on movement of capital and people. Taxation of the same income by two or more countries would constitute a prohibitive burden on the tax-payer. The domestic laws of most countries, including India, mitigate this difficulty by affording unilateral relief in respect of such doubly taxed income (Section 91 of the Income Tax Act). But as this is not a satisfactory solution in view of the divergence in the rules for determining sources of income in various countries, the tax treaties try to remove tax obstacles that inhibit trade and services and movement of capital and persons between the countries concerned. It helps in improving the general investment climate.

The double tax treaties (also called Double Taxation Avoidance Agreements or “DTAA”) are negotiated under public international law and governed by the principles laid down under the Vienna Convention on the Law of Treaties.

The need for Agreement for Double Tax Avoidance arises because of conflicting rules in two different countries regarding chargeability of income based on receipt and accrual, residential status etc. As there is no clear definition of income and taxability thereof, which is accepted internationally, an income may become liable to tax in two countries.

In such a case, the two countries have an Agreement for Double Tax Avoidance, in which case the possibilities are:

1. The income is taxed only in one country.

2. The income is exempt in both countries.

3. The income is taxed in both countries, but credit for tax paid in one country is given against tax payable in the other country.

In India, The Central Government, acting under Section 90 of the Income Tax Act, has been authorized to enter into double tax avoidance agreements (hereinafter referred to as tax treaties) with other countries.

DTAA can be of two types.

i. Comprehensive.

ii. Limited or

Comprehensive DTAAs are those which cover almost all types of incomes covered by any model convention. Many a time a treaty covers wealth tax, gift tax, surtax. Etc. too.

Limited DTAAs are those which are limited to certain types of incomes only, e.g. DTAA between India and Pakistan is limited to shipping and aircraft profits only.

A tax treaty plays the following role:

1. Facilitates investment and trade flow, preventing discrimination between tax payers;

2. Adds fiscal certainty to cross border operations;

3. Prevents international evasion and avoidance of tax;

4. Facilitates collection of international tax;

5. Contributes attainment of international development goal, and

6. Avoids double taxation of income by allocating taxing rights between the source country where income arises and the country of residence of the recipient; thereby promoting cooperation between or amongst States in carrying out their obligations and guaranteeing the stability of tax burden.

The Provisions of DTAA override the general provisions of taxing statute of a particular country. It is now well settled that in India the provisions of the DTAA override the provisions of the domestic statute. Moreover, with the insertion of Sec.90 (2) in the Indian Income Tax Act, it is clear that assessee have an option of choosing to be governed either by the provisions of particular DTAA or the provisions of the Income Tax Act, whichever are more beneficial.

For example under DTAA between Indian and Germany, tax on interest is specified @ 10% whereas under Income Tax Act it is 20%.  Hence, one can follow DTAA and pay tax @ 10%. Further if Income tax Act itself does not levy any tax on some income then Tax Treaty has no power to levy any tax on such income. Section 90(2) of the Income Tax Act recognizes this principle.

There are different models developed over a period of time based on which treaties are drafted and negotiated between two nations. These models assist in maintaining uniformity in the format of tax treaties. They also serve as checklist for ensuring exhaustiveness or provisions to the two negotiating countries.

OECD Model, UN Model, the US Model and the Andean Model are few of such models. Of these the first three are the most prominent and often used models. However, a final agreement could be combination of different models.

OECD Model- Organization of Economic Co-operation and Development (OECD) Model Double Taxation Convention on Income and on Capital, issued in 1977, 1992 and 1995

OECD Model is essentially a model treaty between two developed nations. This model advocates residence principle, that is to say, it lays emphasis on the right of state of residence to tax.

UN Model- United Nations Model Double Taxation Convention between Developed and Developing Countries, 1980

The UN Model gives more weight to the source principle as against the residence principle of the OECD model. As a correlative to the principle of taxation at source the articles of the Model Convention are predicated on the premise of the recognition by the source country that (a) taxation of income from foreign capital would take into account expenses allocable to the earnings of the income so that such income would be taxed on a net basis, that (b) taxation would not be so high as to discourage investment and that (c) it would take into account the appropriateness of the sharing of revenue with the country providing the capital. In addition, the United Nations Model Convention embodies the idea that it would be appropriate for the residence country to extend a measure of relief from double taxation through either foreign tax credit or exemption as in the OECD Model Convention.

Most of India’s treaties are based on the UN Model.

United States Model Income Tax Convention of September, 1996.

The US Model is different from OECD and UN Models in many respects. US Model has established its individuality through radical departure from usual treaty clauses under OECD Model and UN Model.

1) Language used by Treaties

Tax Treaties employ standard International language and standard terms. This is done in order to understand and interpret the same term in the same manner by both assessee as well as revenue. Language employed is technical and stereotyped. Some of the terms are explained below:

i. Contracting State – country which enters into Treaty

ii.  State of Residence- Country where a person resides

iii. State of Source- Country where income arises

iv. Enterprise of a Contracting State- Any taxable unit (including individuals of a Contracting State)

v. Permanent Establishment – A fixed base of an enterprise in the state of Source (usually a branch of a foreign company and in some cases wholly – owned subsidiaries as well)

vi. Income arising in Contracting state – Income arising in a State of a source

One has to read the treaty carefully in order to understand its provisions in their proper perspective. The best way to understand the DTAA is to compare it with an agreement of partnership between two persons. In partnership, the words used are “the party of the first part” and in the DTAA, the words used are “the other contracting state” .One can also replace the words” Contracting States” by names of the respective countries and read the DTAA again , for better understanding.

2) Composition of a comprehensive DTA

Double Tax Avoidance agreements are divided under following heads

In general terms, the Articles of a convention can be divided into six groups for the purpose of analyses:

1. Scope Provisions: these include Article 1 (Personal scope), 2 (Taxes covered), 30 (Entry into force) and 31 (Termination). These provisions determine the persons, taxes and time period covered by a treaty.

2. Definition provisions: these include Article 3 (General Definitions), 4(Residence) and 5 (Permanent Establishment) as well as the definitions of terms in some of the substantive provisions (e.g. the definition of “immovable property” in Article 6(2)).

3. Substantive Provisions: these are the Articles between article 6 and 22 which apply to particular categories of income, capital gains or capital and allocate taxing jurisdiction between the two Contracting States.

4. Provisions for elimination of double taxation: this is primarily Article 23. Article 25(Mutual Agreement) could also be placed in this category.

5. Anti-avoidance provisions: these include Article 9 (Associated Enterprises) and 26 (Exchange of information).

6. Miscellaneous Provisions: this final category includes Articles such as 24(Non-Discrimination), 28 (Diplomats) and 29 (Territorial Extension).

The process of operation of a double taxation convention can be divided into a series of steps, involving the different types of provisions.

1. Determine if the issue is within the scope of the convention:

This involves determining firstly whether the taxpayer is within the personal scope in Article 1- that is, “persons who are residents of one or both Contracting States”. This may involve confirming that the taxpayer is a “person” within in the definition of Article 3(1) (a); it will involve confirming that the taxpayer is resident of a Contracting State according to Article 4(1).

2. Check that the treaty applies to the tax in issue- is it a tax listed in Article 2 (or a tax substantially similar to such a tax).

3. Thirdly, check that the treaty is in operation for the taxable period in issue – that the treaty is in force (Article 29) and has not been terminated (Article 30).

4. Apply the relevant definitions: At this stage the relevant definition provisions (if any) can be applied. Thus, for example, if the taxpayer is a resident of both Contracting States, the tiebreakers in Article 4(2) and (3) have to be applied to determine a single residence for treaty purposes, similarly, if it is necessary to decide whether the taxpayer has a permanent establishment in a state, then Article 5 is relevant.

5. Determine which of the substantive provisions apply: The substantive provisions apply to different categories of income, capital gains or capital; it is necessary to determine which applies. This is a process of characterization. In many cases this may be straightforward; in others the task may not be easy. For example, payments, which are referred to as “royalties”, may in fact fall under Article 7 (Business Profits), 12 (Royalties), 13 (Capital Gains) or 14 (Independent Personal Services). Assistance in characterizing the items can be gained from the Commentaries, case law and reports of the Committee on Fiscal Affairs

6. Apply the substantive article: Substantive articles generally take one of three forms

(i)The state of source may tax without limitation. Examples are: income from house property situated in that state, and business profits derived from a permanent establishment there.

(ii) The state source may tax up to a maximum: here the treaty sets a ceiling to the level of taxation at source. Examples in the OECD Models are: dividends from companies resident in that state and interest derived from there.

(iii)  The state of source may not tax: here, the state of residence of the tax payer alone has jurisdiction to tax. Examples in the OECD Model are: business profit where there is no permanent establishment in the state of source.

7. Apply the provisions for the elimination of double taxation : Every one of the substantive articles must be considered along with article 23 which sets out the methods for the elimination of double taxation.

Ishikawajma Harima Heavy Industries Limited vs. Director of Income Tax, Mumbai Dt. 04/01/2007

In this case, the company was incorporated in Japan. It formed a consortium with four others and entered into an agreement with an Indian firm, Petronet LNG Ltd  for setting up liquefied natural gas receiving and degasification facility in Gujarat. Each member of the consortium was to receive separate payments. The contract involved offshore supply, offshore services, onshore supply, onshore services, construction and erection. The price was payable for offshore supply and services in US dollars, whereas that of onshore supply as also services, construction and erection partly in dollars and partly in rupees.

The dispute arose whether the amounts received by the Japanese corporation from Petronet for offshore supply of equipment and materials were liable to tax under the Indian Income Tax Act and the India-Japan double taxation avoidance treaty. The Authority for Advance Rulings (Income Tax) ruled that the Japanese firm was liable to pay direct tax, even under the treaty. Hence the firm moved the Supreme Court.  It argued that the transactions occurred outside the country. The contract was a divisible one and therefore it did not have any liability to pay tax in regard to offshore services and offshore supply. The government, on the other hand, contended that the contract was a composite one. The supply of goods, whether offshore or onshore, and rendition of service were attributable to the turnkey project.

The Supreme Court ultimately held that the tribunal was wrong and set aside its order.  While the Japanese firm got relief in the case, the judgment is notable for the principles it has laid down to be followed in such cases. Regarding offshore supply of equipment and materials, the Supreme Court laid down nine guidelines in the context of this case, but has general application.

Accordingly,

1. Only such part of the income as attributable to the operations carried out in this country can be taxed here.

2. If all parts of the transfer of goods as well as the payment are carried on outside the country, the transaction cannot be taxed in India.

3. The principle of apportionment, wherein the territorial jurisdiction of a particular state determines its capacity to tax an event, has to be followed.

4. The fact that a contract was signed in India is of no material consequence, if the activities in connection with the offshore supply were outside the country and therefore cannot be deemed to accrue or arise in this country.

5. The court further clarified that there was a distinction between a business connection and a permanent establishment. The latter is for the purpose of assessment of income of a non-resident under a double taxation avoidance agreement while the former is for the application of the Income Tax Act.  As far as offshore services are concerned, the court stated that sufficient territorial nexus between the rendition of services and territorial limits of India is necessary to make the income taxable. The entire contract would not be attributable to the operations in India. The test of residence, as applied in the international law also, is that of the tax payer and not that of the recipient of such services.

6. Regarding Section 9(1)(vii)(c) of the Income Tax Act, dealing with income by way of fees for technical services by a non-resident, the Supreme Court clarified that the services should not only be utilized within India but also be rendered in India or have such a “live link” with India that the entire income became taxable here.

7. Applying the principle of apportionment to composite transactions which have some operations in one territory and some in others, it is essential to determine the taxability of various operations. The location of the source of income within India would not render sufficient nexus to tax the income from that source.

8. There exists a difference between the existence of a business connection and the income accruing or arising out of such business connection.

9. For the profits to be ‘attributable directly or indirectly’, the permanent establishment must be involved in the activity giving rise to the profits.

These guidelines are bound to stand in good stead while dealing with the complex international contracts which are increasingly becoming more common due to globalization.

Websites for reference:

1) Organization of Economic Co-operation and Development (OECD)-http://www.oecd.org

2)United Nations Model Double Taxation Convention between Developed and Developing Countries, 1980-http://unpan1.un.org/intradoc/groups/public/documents/un/unpan004554.pdf

3) United States Model Income Tax Convention of September, 1996 :- http://www.ustreas.gov/offices/tax-policy/library/model996.pdf

4) National website of the Income Tax Department of India-http://www.incometaxindia.gov.in/

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Disclaimer: The contents of this article are for information purposes only and does not constitute advice or a legal opinion and are personal views of the author. It is based upon relevant law and/or facts available at that point of time and prepared with due accuracy & reliability. Readers are requested to check and refer to relevant provisions of statute, latest judicial pronouncements, circulars, clarifications etc before acting on the basis of the above write up.  The possibility of other views on the subject matter cannot be ruled out. By the use of the said information, you agree that Author / TaxGuru is not responsible or liable in any manner for the authenticity, accuracy, completeness, errors or any kind of omissions in this piece of information for any action taken thereof. This is not any kind of advertisement or solicitation of work by a professional.