Tax Treaty Amendment expands information exchange, MAP and introduces a principal purpose test limiting treaty benefits. Protocol amending the India-Oman tax convention updates the Preamble, clarifies taxes covered and competent authorities, revises residency tie breaker ... Summary
Tax Treaty Amendment expands information exchange, MAP and introduces a principal purpose test limiting treaty benefits.
Protocol amending the India-Oman tax convention updates the Preamble, clarifies taxes covered and competent authorities, revises residency tie breaker rules, deletes a provision on air transport, inserts an associated enterprises adjustment mechanism, reduces withholding rates for royalties and technical fees, adds a Non Discrimination article, strengthens the Mutual Agreement Procedure with a three year filing window, expands Exchange of Information obligations, and introduces Assistance in Collection and a Principal Purpose Test denying treaty benefits obtained for principal tax avoidance purposes; the Protocol's entry into force and application rules are specified and notified under section 90(1) of the Income tax Act to give effect in India.
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