https://www.taxtmi.com/news?id=17190 The Protocol amends the DTAA to convert taxation of capital gains on transfer of shares to source-based taxation effective from 1 April 2017, with a grandfathering clause for pre-effective-date investments subject to Limitation of Benefits conditions and a two-year transition regime imposing a reduced tax rate in the source country. It also adds provisions to relieve economic double taxation in transfer pricing cases by expanding MAP access and confirms application of domestic anti-avoidance measures and prevention of tax evasion. en-us Fri, 30 Dec 2016 18:38:49 +0530 Fri, 30 Dec 2016 18:38:49 +0530 TaxTMI RSS Generator https://www.taxtmi.com/news?id=17190 The Protocol amends the DTAA to convert taxation of capital gains on transfer of shares to source-based taxation effective from 1 April 2017, with a grandfathering clause for pre-effective-date investments subject to Limitation of Benefits conditions and a two-year transition regime imposing a reduced tax rate in the source country. It also adds provisions to relieve economic double taxation in transfer pricing cases by expanding MAP access and confirms application of domestic anti-avoidance measures and prevention of tax evasion. News - Fri, 30 Dec 2016 18:38:49 +0530 https://www.taxtmi.com/news?id=17190