Limitation of Benefits denies treaty advantages where the principal purpose of an entity or transaction is tax avoidance.

The Protocol amends the India-UK Convention by redefining person and resident, replacing the dividends and partnerships provisions, expanding exchange of information to include foreseeably relevant documents subject to confidentiality and limited disclosure, and inserting new articles authorising tax examinations abroad, assistance in the collection of taxes under domestic procedures, and a limitation of benefits clause denying treaty benefits where obtaining those benefits was a principal purpose. The Protocol sets entry into force rules and phased application to specified categories of taxes.

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