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Taxation Central Ministry of Finance Income Tax Act, 1961

Ministry of Finance issues notification regarding amendment to India-Brazil Double Taxation Avoidance Agreement (DTAA)

30-Mar-2026 | S.O. 1647(E)

Ministry of Finance has issued notification regarding amendment to India-Brazil DTAA for avoidance of double taxation and prevention of fiscal evasion.

Key Highlights of this notification are:

1. Paragraph "This Convention shall not affect the taxation, by a Contracting State, of its residents except with respect to the benefits granted under Articles 19, 20, 21, 23, 24, 25 and 27" has been included in Article 1.
2. New article 26-A has been inserted after article 26.
3. Paragraph 4 of article 10 has been replaced by "The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of the dividends, being a resident of a Contracting State, carries on business in the other Contracting State of which the company paying the dividends is a resident, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the holding in respect of which the dividends are paid is effectively connected with such permanent establishment or fixed base. In such case the provisions of Article 7 or Article 14, as
the case may be, shall apply."

For more information kindly refer the attached document.

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