India-Kazakhstan tax treaty protocol enters into force

A tax treaty protocol between India and Kazakhstan has entered into force, India’s Central Board of Taxes announced April 13.

The India-Kazakhstan protocol updates the countries’ December 1996 tax treaty, allowing for relief from double taxation in transfer pricing cases and providing a new services permanent establishment provision.

The protocol adds a new limitation on benefits article to prevent tax treaty shopping. This provision incorporates a “main purpose” test and allows for the application of domestic law and measures in instances of tax evasion or avoidance.

Further, new the protocol updates the existing treaty’s provisions on exchange of information for tax purposes.

The new protocol entered into force on March 12.