Double taxation agreement amendments reduce withholding rates and set place of effective management as tie breaker for residency. Second Protocol amends the India-New Zealand tax convention: expands the definition of India to include maritime zones and airspace; establishes place of effective management as the residency tie breaker for persons other than individuals; confirms source taxation of income and capital gains from immovable property in the State where the property is situated; reduces withholding rates in Articles 10, 11 and 12; revises non discrimination text for permanent establishments and inserts an anti avoidance clause; and sets entry into force and operative date rules.