India and Kazakhstan have signed a protocol to amend their 1996 tax treaty, the Indian government announced today.
The new India-Kazakhstan protocol would allow for relief from double taxation in transfer pricing cases, the government said.
Moreover, the protocol also adds a new services permanent establishment (PE) provision with a threshold and provides that profits attributed to a PE will be determined on the basis of apportionment of the total profits of the enterprise.
Further, the India-Kazakhstan protocol would add updated provisions on exchange of information, and a main purpose test to prevent misuse of the treaty.
The protocol is not yet in force.