Exchange of Information expanded to permit broad tax information sharing and mutual assistance in tax collection between the two States. Three Protocols amend the India-New Zealand tax Convention: the First Protocol makes New Zealand's competent authority able to decline to treat a New Zealand resident as having paid Indian tax under Article 23(3) where arrangements, third party benefits, fraud or avoidance, or other relevant circumstances so warrant, and sets entry into force notifications; the Second Protocol expands the definition of India, provides a place of effective management tie breaker for non individual dual residency, affirms source taxation of immovable property, reduces specified withholding rates, and adds an anti avoidance carve out to PE non discrimination; the Third Protocol replaces Article 26 to broaden exchange of information and adds Article 26A establishing mutual assistance in collection of taxes with defined limits and procedures.
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Provisions expressly mentioned in the judgment/order text.
Exchange of Information expanded to permit broad tax information sharing and mutual assistance in tax collection between the two States.
Three Protocols amend the India-New Zealand tax Convention: the First Protocol makes New Zealand's competent authority able to decline to treat a New Zealand resident as having paid Indian tax under Article 23(3) where arrangements, third party benefits, fraud or avoidance, or other relevant circumstances so warrant, and sets entry into force notifications; the Second Protocol expands the definition of India, provides a place of effective management tie breaker for non individual dual residency, affirms source taxation of immovable property, reduces specified withholding rates, and adds an anti avoidance carve out to PE non discrimination; the Third Protocol replaces Article 26 to broaden exchange of information and adds Article 26A establishing mutual assistance in collection of taxes with defined limits and procedures.
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