Exchange of Information expanded to permit routine and on request tax data sharing and cross border collection assistance.

The Protocol replaces Article 27 with a comprehensive Exchange of Information clause requiring routine and on request exchange of information for administering covered taxes, preserving confidentiality and limiting disclosure to authorised uses while obliging States to employ available information gathering measures subject to enumerated exceptions. It inserts Article 27A establishing Assistance in the Collection of Taxes, defining "revenue claim", requiring requested States to collect or take conservancy measures under their domestic law as if the claim were their own, and setting limits including public policy, prior collection efforts, and disproportionate administrative burden. The Central Government notifies implementation under section 90(1) of the Income tax Act.

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