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........