Amending the Agreement between the Government of the United Arab Emirates and the Government of the Republic of India for the avoidance of double taxation - 282/2007 - Income Tax

Tax residency redefined and limitation of benefits added to the amended UAE-India double tax protocol affecting treaty relief.

The Protocol revises the Agreement by redefining resident status-India by liability to tax and exclusion of persons taxable only on source income; UAE by physical presence and corporate incorporation with management and control-and recognises specified government institutions. It permits deductions for permanent establishment expenses under the taxing State's laws, allows source State taxation of dividends subject to a cap for the beneficial owner, reallocates capital gains taxing rights for shares deriving value from immovable property, exempts government income from tax in the other State, revises nondiscrimination for permanent establishments, and adds a Limitation of Benefits clause denying benefits to entities formed to obtain treaty advantages.