Finance Ministry

CBDT amends DTAC between India and Kazakhstan-Salient Features

CBDT notifies the Protocol amending the Double Taxation Avoidance Convention (DTAC) between India and Kazakhstan. 

A Protocol to amend the existing Double Taxation Avoidance Convention (DTAC) between India and Kazakhstan, earlier signed on 9th December, 1996 for the avoidance of double taxation and for the prevention of fiscal evasion with respect to taxes on income, was signed on 06.01.2017. The said Protocol has entered into force on 12.03.2018 and was notified in Official Gazette on 12.04.2018.

CBDT amends DTAC between India and Kazakhstan-Salient Feature

Salient features of the Protocol are as under:

(i)  The Protocol provides internationally accepted standards for effective exchange of information on tax matters. Further, the information received from Kazakhstan for tax purposes can be shared with other law enforcement agencies with the authorisation of the competent authority of Kazakhstan and vice versa.

(ii)  The Protocol inserts a 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.

(iii)  The Protocol inserts specific provisions to facilitate relieving of economic double taxation in transfer pricing cases. This is a taxpayer friendly measure and is 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.

 (iv) The Protocol replaces the existing Article on Assistance in Collection of Taxes with a new Article to align it with international standards.

Source: PIB

Share

Recent Posts

  • Income Tax

Agricultural land is outside the deeming provision u/s 56(2)(x) – ITAT

Agricultural land is outside the definition of capital asset, therefore, the deeming provision u/s 56(2)(x) cannot be invoked - ITAT…

5 hours ago
  • Income Tax

NSDL latest e-TDS TCS RPU Version 1.2 for Tax Year 2026-27 – Download

NSDL latest e-TDS TCS RPU version 1.2 for Tax Year 2026-27 NSDL has revised the e-TDS TCS RPU utility for…

9 hours ago
  • Income Tax

Deprecation allowable u/s 11(6) if capital expenditure not claimed as application of income

Assessee entitled to claim deprecation u/s 11(6) if corresponding capital expenditure was not claimed as application of income - ITAT…

1 day ago
  • Income Tax

CBDT cautions CAs issuing certificates in Form 15CB/Form146 to exercise due care & diligence

Chartered Accountants issuing certificates in Form 15CB/Form146 are expected to exercise due care, diligence and professional judgment – CBDT CBDT…

1 day ago
  • Income Tax

Section 292C carry no presumption of correctness of seized documents contents against third party

Section 292C of the Income Tax Act 1961 indeed carries presumption of correctness of such seized documents contents but only…

3 days ago
  • Income Tax

Condonation of delay u/s 119(2)(b) for filing revised return to avail benefits u/s 44ADA

PCIT directed to consider condonation of delay u/s 119(2)(b) in filing revised return to availing benefits of section 44ADA In…

3 days ago