Double taxation relief agreements preserve domestic anti-avoidance and branch profit tax rules despite treaty benefits.

Central Government may enter into or adopt agreements with foreign governments or specified territories to provide relief from double taxation, exchange information to prevent tax evasion or avoidance, recover tax, and pursue other Code purposes; such agreements are implemented by notification, may be concluded by specified associations, and require a certificate of residence for treaty relief. Treaty provisions favourable to the assessee apply, except that the General Anti-Avoidance Rule, Branch Profit Tax and Controlled Foreign Company rules remain applicable despite treaty benefits.

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