Exchange of information obligations expanded to require foreseeable tax relevant data sharing, with confidentiality and usage limits.

The Protocol amends the India-Slovenia tax Convention by clarifying definitions of "tax" and "fiscal year," confirming that immovable property income and related capital gains may be taxed by both States subject to Article 23, and setting a residency rule for visiting individuals for Article 20. It permits differential taxation of profits attributable to permanent establishments within a capped rate difference. It replaces Article 26 with expanded Exchange of Information obligations and inserts Article 27 on Assistance in the Collection of Taxes, requiring cooperation in collection and conservancy measures subject to domestic law limits, confidentiality, and proportionality constraints.

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