Residence and management tests clarified: treaty defines ordinary residence and place of management for tax purposes. The Protocol clarifies that 'ordinarily resides' and 'normally managed or controlled' follow Hong Kong law, detailing criteria for individual residence and for where companies are managed; it defines 'right of abode' per Hong Kong law; includes certain default additions and 'additional tax' within 'penalty or interest'; extends territorial scope to include Shenzhen Bay Port Hong Kong Port Area; limits exchange of information disclosure to non third jurisdiction use while permitting specified Indian oversight bodies to access information, allows retroactive information disclosure if foreseeably relevant, and applies exchange rules to additional India administered taxes, with a mutual review provision.