Kazakhstan has ratified a protocol containing amendments to a tax treaty signed with India, Kazakh international news agency, Kazinform, reported on February 8.
The India-Kazakhstan protocol would amend the countries 1996 treaty, allowing for relief from double taxation in transfer pricing cases and providing a new services permanent establishment (PE) provision with a threshold.
The treaty also 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 adds updated provisions on exchange of information, and a main purpose test to prevent misuse of the treaty.
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