Exchange of information expands mutual tax information sharing with confidentiality limits and obligations to obtain requested data under DTAA. The Protocol amends definitions and replaces the Agreement's exchange-of-information article: it limits 'political sub-division' to India, specifies factors for determining the place of effective management, defines fixed base for independent services, and mandates that competent authorities exchange foreseeably relevant information (including certified documents) for tax administration. Information must be kept secret and disclosed only to authorized persons for tax assessment, enforcement, appeals or oversight, subject to domestic-law limits and protections for trade secrets and public policy, while obliging States to obtain requested information even without a domestic interest.
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Provisions expressly mentioned in the judgment/order text.
Exchange of information expands mutual tax information sharing with confidentiality limits and obligations to obtain requested data under DTAA.
The Protocol amends definitions and replaces the Agreement's exchange-of-information article: it limits "political sub-division" to India, specifies factors for determining the place of effective management, defines fixed base for independent services, and mandates that competent authorities exchange foreseeably relevant information (including certified documents) for tax administration. Information must be kept secret and disclosed only to authorized persons for tax assessment, enforcement, appeals or oversight, subject to domestic-law limits and protections for trade secrets and public policy, while obliging States to obtain requested information even without a domestic interest.
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