https://www.taxtmi.com/acts?id=43491 The amending protocol to the India-Brazil double taxation convention preserves domestic anti-avoidance and anti-evasion measures, clarifies the scope of covered taxes and the meaning of "tax," and excludes penalties, fines, defaults, and omissions from tax credit treatment. It also addresses corresponding adjustments, company-equity interest, technical assistance payments, approved cultural institutions, and the compatibility of Brazilian royalty deductibility rules with the non-discrimination article. The protocol replaces the exchange-of-information article with a broader regime requiring foreseeable-relevance information exchange, confidentiality, use of information-gathering powers, and no refusal solely because information is held by banks, fiduciaries, nominees, or relates to ownership interests. en-us Mon, 15 Jul 2024 12:21:10 +0530 Tue, 31 Mar 2026 15:01:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=43491 The amending protocol to the India-Brazil double taxation convention preserves domestic anti-avoidance and anti-evasion measures, clarifies the scope of covered taxes and the meaning of "tax," and excludes penalties, fines, defaults, and omissions from tax credit treatment. It also addresses corresponding adjustments, company-equity interest, technical assistance payments, approved cultural institutions, and the compatibility of Brazilian royalty deductibility rules with the non-discrimination article. The protocol replaces the exchange-of-information article with a broader regime requiring foreseeable-relevance information exchange, confidentiality, use of information-gathering powers, and no refusal solely because information is held by banks, fiduciaries, nominees, or relates to ownership interests. Act-Rules DTAA Mon, 15 Jul 2024 12:21:10 +0530 https://www.taxtmi.com/acts?id=43491