India and Kazakhstan Amend Existing DTA

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.

Amended DTA in line with BEPS

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.

Permanent Establishment

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.

Sources: Indian Express, India Today
 

TPA BEPS Desk

Transfer Pricing Associates introduces TPA BEPS Desk. If you have any questions, or need more detailed advice on any aspects of BEPS related issues, please get in touch with us. The TPA Global network has alliance partners throughout the world, and the network can provide multi-disciplinary approach on today's critical transfer pricing challenges faced by multinational enterprises.

Copyright © 2017
Transfer Pricing Associates BV.
All rights reserved.

H.J.E. Wenckebachweg 210
1096 AS Amsterdam
T: +31 20 462 3530
E: info@tpa-global.com
I: www.tpa-global.com