MANU/CBDT/0026/2023
Ministry : Ministry of Finance
Department/Board : CBDT
Notification No. : 24/2023
Date of Notification : 03.05.2023
Date of Publication : 03.05.2023
Central Government notifies that all the provisions of Agreement and Protocol specified shall be given effect to in the Union of India
S.O.2059(E).--Whereas, an Agreement and Protocol between the Government of the Republic of India and the Government of the Republic of Chile for the elimination of double taxation and the prevention of fiscal evasion and avoidance with respect to taxes on income, was signed at Chile on the 9th day of March, 2020, as set out in the
Annexure to this notification (hereinafter referred to as the Agreement and Protocol);
And whereas, the said Agreement and Protocol entered into force on the 19th
day of October, 2022, being the date of the later of the notifications of the
completion of the procedures required by the respective laws of the Contracting
States for entry into force of the said Agreement and Protocol, in accordance
with paragraph 1 of Article 30 of the said Agreement;
And whereas, sub-paragraph (a) of paragraph 2 of Article 30 of the said Agreement provides that the provisions of the Agreement shall have effect in India in respect of income derived in any fiscal year beginning on or after the first day of April next following the date on which the Agreement 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 Government
hereby notifies that all the provisions of said Agreement and Protocol, as
annexed hereto, shall be given effect to in the Union of India.
ANNEXURE AGREEMENTBETWEEN
THE REPUBLIC OF INDIA AND
THE REPUBLIC OF CHILE
FOR THE ELIMINATION OF DOUBLE TAXATION
AND THE PREVENTION OF FISCAL EVASION AND AVOIDANCE WITH RESPECT TO TAXES ON INCOME
The Government of the Republic of India and the Government of the Republic of Chile,
Desiring to further develop their economic relationship and to enhance their cooperation in tax matters,
Intending to conclude an Agreement for the elimination of double taxation with respect to taxes on income without creating opportunities for non-taxation or reduced taxation through tax evasion or avoidance (including through treaty-shopping arrangements aimed at obtaining reliefs provided in this Agreement for the indirect benefit of resid........