Quick Summary
The Government of India has officially notified the Protocol amending the 1997 Double Taxation Avoidance Agreement (DTAA) between India and the Sultanate of Oman. The amendment, formalized through Notification No. 69/2025, was signed in Muscat on January 27, 2025, and came into effect on May 28, 2025. The revised treaty provisions will apply in India for income derived in any fiscal year starting on or after April 1, 2026. Key Highlights of the Amended Protocol Anti-Treaty Abuse Measure
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FAQ :
The Protocol amending the DTAA came into effect on May 28, 2025, and its revised provisions will apply in India for fiscal years starting on or after April 1, 2026.
The maximum withholding tax rate for royalties and technical service fees has been reduced to 10%, down from the previous 15%.
The PPT is an anti-abuse clause that disallows treaty benefits if the primary aim of a transaction was to gain tax advantages, unless it aligns with the treaty's original intent.
Taxpayers now have the right to seek relief against taxation not in accordance with the DTAA within three years, irrespective of domestic legal remedies.
The amendment allows for a broader exchange of tax-related information, including banking data, and provides mutual assistance in tax recovery.
Yes, a new Article 25A ensures that nationals or enterprises of one country are not subjected to more burdensome taxation in the other country.
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