Limitation of benefits rule restricts treaty gains preferences where arrangements primarily aim to obtain preferential capital gains treatment. The Protocol amends the India-Mauritius tax Convention to: treat prolonged service provision through personnel as creating a permanent establishment when activities exceed an aggregate of 90 days in any 12 month period; limit source withholding on interest to 7.5% with a dated bank interest exemption; introduce a Fees for Technical Services Article permitting source taxation with a 10% cap and detailed sourcing and anti abuse rules; permit source taxation of certain post cut off-date share gains with a transitional capped rate; broaden other income sourcing; expand exchange of information; add assistance in tax collection; and add a limitation of benefits rule targeting shell/conduit entities.