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2019-10-26

【Cross-Border Tax】

TAX AGREEMENTS: India and China tighten treaty anti-abuse measures

India and China have modified their double taxation agreement (DTA) to add various measures from the OECD's Base Erosion and Profit Shifting (BEPS) initiative, in particular a mechanism to prevent treaty shopping. It also covers all Chinese individual and enterprise income taxes, rather than just foreign enterprises or enterprises with foreign investments. The definition of 'permanent establishment' has been changed to leave no scope of confusion as to whether an establishment is subject to the DTA or not.

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