Ask Jurishour AI

Generic selectors
Exact matches only
Search in title
Search in content
Post Type Selectors
tdb_templates
saswp_reviews
saswp-collections
saswp_rvs_location
tdc-review-email
web-story-font
web-story
googlesitekit_email
tds_locker
tds_email
saswp
mailpoet_page
mailpoet_email
tdcpt_tunes
tdc-review
pronamic_payment
pronamic_gateway
pronamic_pay_subscr
wpcode
HomeNotificationIndia and Oman Ink Protocol to Strengthen DTAA: 7 Key Amendments

India and Oman Ink Protocol to Strengthen DTAA: 7 Key Amendments

Published on

🚀 Stay Connected With JurisHour

WhatsApp X Telegram

The Ministry of Finance has notified the amendment in Double Taxation Avoidance Agreement (DTAA) between India and the Sultanate of Oman through a new protocol signed on January 27, 2025, in Muscat, which is effective from May 28, 2025.

The protocol modernizes several key aspects of the 1997 DTAA between the two countries and aligns the agreement with contemporary international tax standards, particularly those advocated by the OECD and G20.

Reduced Tax Rates

The withholding tax on royalties and technical fees has been reduced from 15% to 10%, benefiting companies involved in technology transfer and intellectual property use.

Anti-Abuse Provisions Introduced

A new Article 27B includes a Principal Purpose Test (PPT), which denies treaty benefits if one of the main purposes of any transaction is to obtain such benefits inappropriately. This aims to curb treaty shopping and round-tripping.

Expanded Information Exchange

Article 27 now allows for a broader and more efficient exchange of tax-related information between the two governments, including data held by banks and financial institutions.

Assistance in Tax Collection

A new Article 27A provides a legal framework for mutual assistance in the recovery and enforcement of tax claims, bolstering cross-border tax administration and compliance.

Non-Discrimination Clause

Article 25A prohibits tax discrimination against foreign nationals or enterprises, ensuring fair treatment of Omani businesses in India and vice versa.

Updated Definitions and Technical Clarifications

Terms like “competent authority”, “tax year”, and rules for determining residency for entities with dual residence have been revised for better clarity and application.

Deletion of Outdated Provisions

Certain redundant paragraphs, such as Paragraph 5 of Article 8 and Paragraph 4 of Article 25 in the original agreement, have been deleted to streamline the text.

The revised protocol will apply in India for income derived from fiscal years beginning on or after April 1, 2025, and in Oman for income derived in any tax year following the protocol’s entry into force.

Notification Details

Notification No. 69/2025

Date: 25/06/2025

Click Here To Read Notification

Mariya Paliwala
Mariya Paliwalahttps://www.jurishour.in/
Mariya is the Senior Editor at Juris Hour. She has 7+ years of experience on covering tax litigation stories from the Supreme Court, High Courts and various tribunals including CESTAT, ITAT, NCLAT, NCLT, etc. Mariya graduated from MLSU Law College, Udaipur (Raj.) with B.A.LL.B. and also holds an LL.M. She started her career as a freelance tax reporter in the leading online legal news companies.

Latest articles

Management, Technical Services Rendered From China Not Taxable as FTS Under India-China DTAA: ITAT

The Delhi Bench of the Income Tax Appellate Tribunal (ITAT) has held that payments...

CGST Corruption Case: Allahabad HC Grants Bail to Advocate After 9 Months in Custody

The Allahabad High Court, Lucknow Bench, has granted bail to 70-year-old advocate Naresh Kumar...

CBDT Removes Arrest Provision for Tax Recovery

The Central Board of Direct Taxes (CBDT) has amended the Income-tax Rules, 2026, bringing...

CBDT Revises Valuer and Income-tax Practitioner Forms, Extends Key Deadlines

The Central Board of Direct Taxes (CBDT) has notified the Income-tax (Fourth Amendment) Rules,...

More like this

Management, Technical Services Rendered From China Not Taxable as FTS Under India-China DTAA: ITAT

The Delhi Bench of the Income Tax Appellate Tribunal (ITAT) has held that payments...

CGST Corruption Case: Allahabad HC Grants Bail to Advocate After 9 Months in Custody

The Allahabad High Court, Lucknow Bench, has granted bail to 70-year-old advocate Naresh Kumar...

CBDT Removes Arrest Provision for Tax Recovery

The Central Board of Direct Taxes (CBDT) has amended the Income-tax Rules, 2026, bringing...