The protocol to the 1994 income tax treaty between China and India entered into force on 5 June 2019. The protocol, signed 26 November 2018, is the first to amend the treaty and includes the following changes:
- The replacement of the title and preamble in line with BEPS standards;
- The replacement of Article 1 (Persons Covered), including that income derived by or through an entity or arrangement that is established in either Contracting State and that is treated as wholly fiscally transparent…