Exchange of information obligation expanded to require sharing foreseeably relevant tax data while maintaining confidentiality protections. The Protocol clarifies that immovable property income may be taxed in both States, treats India's Government as including political sub-divisions for deeming interest, royalties and technical fees to arise where the payer is a political sub-division, and replaces Article 26 with an expanded Exchange of Information obligation requiring competent authorities to exchange foreseeably relevant tax information, protect confidentiality, limit disclosure to specified tax purposes unless authorised, employ information gathering measures even without domestic interest, and not decline requests solely because information is held by banks, nominees or fiduciaries.
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Provisions expressly mentioned in the judgment/order text.
Exchange of information obligation expanded to require sharing foreseeably relevant tax data while maintaining confidentiality protections.
The Protocol clarifies that immovable property income may be taxed in both States, treats India's Government as including political sub-divisions for deeming interest, royalties and technical fees to arise where the payer is a political sub-division, and replaces Article 26 with an expanded Exchange of Information obligation requiring competent authorities to exchange foreseeably relevant tax information, protect confidentiality, limit disclosure to specified tax purposes unless authorised, employ information gathering measures even without domestic interest, and not decline requests solely because information is held by banks, nominees or fiduciaries.
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