On January 6, The Central Board of Direct Taxation (CBDT) announced that India and Kazakhstan have signed a protocol to amend the existing Double Taxation Avoidance Agreement.
The CBDT informed that the amended version is a taxpayer-friendly measure, which is in line with India’s commitment under the Base Erosion and Profit Shifting (BEPS) Action Plan to meet the minimum standard of providing Mutual Agreement Procedure (MAP) access in transfer pricing cases.
The two countries signed the initial DTA Agreement on December 9th, 1996 for the avoidance of double taxation and for the prevention of fiscal evasion with respect to taxes on income.
The protocol also includes service PE (permanent establishment) provisions with a threshold and also provides that the profits to be attributed to a PE will be determined on the basis of apportionment of total profits of the enterprise.
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