<h1>Dividend taxation restructured with preferential treatment for substantial holdings and altered withholding for other shareholders.</h1> The Amending Protocol reallocates taxing rights on capital gains from sale of company shares to the jurisdiction of the company's residence, removes the Most Favoured Nation clause, introduces a split dividend withholding regime that differentiates substantial holders from other shareholders, aligns the definition of Fees for Technical Services with the India-US model, and expands Permanent Establishment to include a Service PE; it also enhances Exchange of Information, adds Assistance in Collection of Taxes, and incorporates applicable BEPS MLI provisions, subject to each Party's internal procedures for entry into effect.