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TMI BlogAgreement between the Government of the Republic of India and the State of Israel for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to TaxesX X X X Extracts X X X X X X X X Extracts X X X X ..... hereas, the said Protocol has entered into force on the 19th day of December, 2016, being the date of the last notification of the completion of the procedures as required by the respective laws for entry into force of the said Protocol, in accordance with Article 6 of the said Protocol; And whereas, clause (a) of Article 6 of the said Protocol provides that the provisions of the Protocol shall have effect in India in respect of taxes on income, and taxes on capital, for fiscal year beginning on or after the first day of April next following the date on which the said Protocol enters into force; Now, therefore, in exercise of the powers conferred by sub-section (1) of section 90 of the Income-tax Act, 1961 (43 of 1961), the Central Govern ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e of the alienation or at any time during the twelve preceding months); or b) an interest in a partnership, trust or other entity, deriving more than 50 per cent of its value directly or indirectly from immovable property situated in that other State (at the time of the alienation or at any time during the twelve preceding months); may be taxed in that other State." Article 2 Paragraphs 3 and 4 of Article 24 (Elimination of Double Taxation) of the Convention are omitted. Article 3 The Convention is amended by omitting Article 27 and substituting it with the following: "Article 27 EXCHANGE OF INFORMATION 1. The competent authorities of the Contracting States shall exchange such information (including documents) as is forseeably rele ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... r Contracting State; (b) to supply information (including documents) which is not obtainable under the laws or in the normal course of the administration of that or of the other Contracting State; (c) to supply information which would disclose any trade, business, industrial, commercial or professional secret or trade process, or information, the disclosure of which would be contrary to public policy (ordre public). 4. If information is requested by a Contracting State in accordance with this Article, the other Contracting State shall use its information gathering measures to obtain the requested information, even though that other State may not need such information for its own tax purposes. The obligation contained in the preceding sen ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rements for entry into force of this Amending Protocol. The Amending Protocol, which shall form an integral part of the Convention, shall enter into force on the date of the last notification, and thereupon shall have effect: (a) in case of India, in respect of taxes on income, and taxes on capital, for fiscal years beginning on or after the first day of April next following the date on which the Amending Protocol enters into force; (b) in case of Israel, in respect of taxes on income, and taxes on capital, for taxable periods beginning on or after the first day of January next following the date on which the Amending Protocol enters into force; (c) for the purposes of Article 27 (Exchange of Information) of the Convention, from the date ..... X X X X Extracts X X X X X X X X Extracts X X X X
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