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of <h1>India-Uruguay Protocol clarifies tax rules for international transport, interest, and information exchange under Double Taxation Agreement.</h1> The Protocol outlines provisions integral to the Double Taxation Avoidance Agreement between India and Uruguay. It clarifies that individuals taxed under Uruguay's territorial principle are included within the agreement's scope. Profits from international container transport by a resident transportation enterprise are taxable only in the resident state unless used solely within the other state. Interest on investments related to international shipping or aircraft operations is treated as operational profits, exempt from Article 11. The source state retains taxation rights if income is untaxed in the resident state. The Protocol permits higher taxes on foreign permanent establishments and allows India to share information with its law enforcement agencies. The exchange of information provisions is effective from the fiscal year following the agreement's entry into force.
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