The protocol to the 1994 income tax treaty between China and India was signed on 26 November 2018. The protocol 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 under the tax law of either …