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of <h1>India-Portugal Tax Protocol: Clarifications on Income Timing, Capital Gains, Permanent Establishments, and Data Protection Measures</h1> The Protocol forms an integral part of the Convention between India and Portugal to avoid double taxation and prevent fiscal evasion on income taxes. It clarifies various articles: Article 3 specifies the timing of income application; Articles 3 and 23 exclude penalties from the term 'tax'; Article 5 defines a warehouse as a permanent establishment; Article 6 allows the resident state to tax property income; Article 7 relates to India's Income Tax Act section 44C; Article 13 allows resident states to tax capital gains; Article 23 defines 'economic development'; and Article 24 addresses thin capitalization and tax rate differences. Article 26 mandates data protection measures.
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