Double taxation relief: partnership shares, permanent establishment profit apportionment and collection-assistance provisions clarified under the treaty.

The Protocol clarifies that an Irish resident's share of partnership profits from a partnership resident in India remains taxable in Ireland but is treated as income from Indian sources for Article 23 credit purposes; permits a Contracting State to apportion total enterprise profits to determine taxable profits of an insurance permanent establishment provided the method conforms to Article 7 principles; allows India to tax a permanent establishment of an Irish company at a higher rate than similar domestic companies without contravening Article 24; and records Ireland's commitment to negotiate collection-assistance provisions if its domestic law changes, alongside agreed temporal amendments substituting calendar-year references for certain fiscal-year dates.

---

---

---