Limitation of Benefits: treaty restricts treaty access and expands exchange of information affecting cross border capital gains taxation. The Amending Protocol broadens capital gains taxation by allowing a State to tax gains from alienation of shares or interests when more than 50% of their value is derived from immovable property in that State, strengthens Exchange of Information obligations requiring competent authorities to exchange foreseeably relevant tax information subject to confidentiality and limited exceptions (notwithstanding bank secrecy or fiduciary status), and introduces a Limitation of Benefits clause denying treaty benefits where obtaining treaty advantages is a main purpose and requiring beneficial ownership for entitlement; it enters into force upon mutual notification and applies in India from the fiscal year beginning on or after the first April following entry into force.