Exchange of information under India-Brazil tax treaty expanded with broader cooperation and confidentiality rules. The amending protocol to the India-Brazil double taxation convention preserves domestic anti-avoidance and anti-evasion measures, clarifies the scope of covered taxes and the meaning of 'tax,' and excludes penalties, fines, defaults, and omissions from tax credit treatment. It also addresses corresponding adjustments, company-equity interest, technical assistance payments, approved cultural institutions, and the compatibility of Brazilian royalty deductibility rules with the non-discrimination article. The protocol replaces the exchange-of-information article with a broader regime requiring foreseeable-relevance information exchange, confidentiality, use of information-gathering powers, and no refusal solely because information is held by banks, fiduciaries, nominees, or relates to ownership interests.
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Exchange of information under India-Brazil tax treaty expanded with broader cooperation and confidentiality rules.
The amending protocol to the India-Brazil double taxation convention preserves domestic anti-avoidance and anti-evasion measures, clarifies the scope of covered taxes and the meaning of "tax," and excludes penalties, fines, defaults, and omissions from tax credit treatment. It also addresses corresponding adjustments, company-equity interest, technical assistance payments, approved cultural institutions, and the compatibility of Brazilian royalty deductibility rules with the non-discrimination article. The protocol replaces the exchange-of-information article with a broader regime requiring foreseeable-relevance information exchange, confidentiality, use of information-gathering powers, and no refusal solely because information is held by banks, fiduciaries, nominees, or relates to ownership interests.
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