Govt. Notifies Protocol Amending India-Brazil DTAA

Notification No. 39/2026, dated 30-03-2026

The Central Board of Direct Taxes (CBDT) has notified a Protocol amending the Convention and the Protocol between the Government of the Republic of India and the Government of the Federative Republic of Brazil for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income.

1. Background of the Amendment

The existing Double Taxation Avoidance Agreement (DTAA) between India and Brazil governs the taxation of cross-border income and aims to:

• Prevent double taxation
• Provide certainty in tax treatment
• Facilitate bilateral trade and investment

The notified Protocol updates specific provisions of this Convention.

2. Objective of the Protocol

The amendment seeks to:

• Align the DTAA with international tax standards and evolving global practices
• Strengthen measures for the prevention of tax evasion and avoidance
• Enhance clarity and efficiency in tax administration between the two countries

3. Implications of the Amendment

The revised Protocol is expected to:

• Impact the taxation of cross-border income flows between India and Brazil
• Provide greater certainty to taxpayers and businesses
• Improve exchange of information and cooperation between tax authorities

4. Conclusion

The notification of the amended Protocol reinforces India’s commitment to maintaining robust and updated tax treaties, supporting international economic cooperation while ensuring effective safeguards against tax avoidance.

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