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of <h1>Mutual Tax Collection Assistance Under Article 28 of DTAA: Key Provisions and Limitations Explained</h1> Article 28 of the Double Tax Avoidance Agreement (DTAA) between two Contracting States outlines mutual assistance in tax collection. It defines 'revenue claim' as any tax-related amount owed, including interest and penalties. A revenue claim enforceable in one state can be collected by the other state as if it were its own, following its laws. The article also allows for conservancy measures to ensure collection. However, such claims do not gain priority or time-limit protections in the assisting state. Disputes over claims must be resolved in the originating state, and assistance is not required if it contradicts laws, public policy, or imposes disproportionate administrative burdens.
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