CBDT amends the Double Taxation Avoidance Convention (DTAC) agreement between India and Kazakhstan
New Delhi, Apr 16 (KNN) A central Board of direct Taxes, Government of India has notified the protocol to amend the existing Double Taxation Avoidance Convention (DTAC) between Indi and Kazakhstan to prevent fiscal evasion and double taxation.
The protocol as per the amendments provides internationally accepted standards for effective exchange of information on tax matter.
Further, the information received from Kazakhstan for tax purposes can be shared with other law enforcement agencies with the authorization of the competent authority of Kazakhstan and vice versa.
The protocol also includes the Limitation of Benefits Article to provide a main purpose test to prevent misuse of the DTAC and to allow application of domestic law and measures against tax avoidance or evasion.
Specific provisions have also been included in the protocol to facilitate relieving of economic double taxation in transfer pricing cases in line with India’s commitment under Base Erosion and Profit Shifting (BEPS) Action Plan to meet the minimum standard of providing Mutual Agreement Procedure (MAP) access in transfer pricing cases.
Also to align with international standards the Protocol replaces the existing Article on Assistance in Collection of Taxes with a new Article.
Both the countries signed the agreement on DTAC earlier in 9th Dec 1996, and lately signed a protocol to amend the existing DTAC on 6 Jan 2017, which was notified in official Gazette on 12 March 2018. (With PIB inputs)