Govt. notifies amended Protocol of India & Belgium for DTAA & Fiscal Evasion of taxes

Central Government notifies amended Protocol between India and Belgium for Avoidance of Double Taxation and the Prevention of Fiscal Evasion of taxes.

Central Government notifies the Protocol amending the Agreement and the Protocol between the Government of the Republic of India and the Government of the Kingdom of Belgium for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to taxes on Income.

The Protocol between the Government of the Republic of India and the Government of the Kingdom of Belgium for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, was signed at Brussels on the 26th April, 1993.

Subsequently, the Protocol, amending the Agreement was signed at New Delhi on the 9th March, 2017 (Amending Protocol). The date of entry into force of the said Amending Protocol is the 26th June, 2025, being the date of the later of the notifications of the completion of the legal requirements and procedures for giving effect to the said Amending Protocol.

In exercise of the powers conferred by sub-section (1) of section 90 of the Income-tax Act, 1961 (43 of 1961), the Central Government has notified that all the provisions of the said Amending Protocol shall be given effect to in the Union of India.

The Annexure to Amending Protocol consists of four Articles.

Article – 1 : The term “criminal tax matters” has been defined to mean tax matters involving intentional conduct, whether before or after the entry into force of this Agreement, which is liable to prosecution under the criminal laws and/or the tax laws of the applicant Party.

Article -2 : Article 26 of the Protocol related to exchange of information is amended

Article -3: Article 27 (Aid and Assistance in Recovery) of the Agreement is replaced by the amended Article.

Article – 4 : The Governments of the Contracting States shall notify each other through diplomatic channels that all legal requirements and procedures for giving effect to this Amending Protocol have been satisfied.

Download Notification No. 160/2025 Click Here >>

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