The Central Government has issued Notification No. 39/2026 [F. No. CBDT/1/2022-FT&TR Division] dated March 30, 2026, notifying the Protocol amending the Convention between India and Brazil for avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income.
The amending Protocol, signed on 24 August 2022, has entered into force on 18 October 2025 after completion of necessary legal procedures by both countries. The provisions of the Protocol will take effect in India from the financial year following its entry into force, i.e., from April 2026 onwards.
The revised treaty introduces updated provisions to align with international standards, including measures to prevent tax avoidance, curb treaty abuse, and enhance clarity in taxation of cross-border income. It also incorporates changes relating to permanent establishment, dividends, interest, royalties, and introduces provisions on fees for technical services.
This amendment reflects India’s continued commitment to strengthening international tax cooperation, ensuring fair taxation, and facilitating cross-border trade and investment between India and Brazil.
The Complete Notification can be accessed at: https://a2ztaxcorp.net/wp-content/uploads/2026/03/CBDT-NN-39-PROTOCOL-AMENDING-THE-CONVENTION-BETWEEN-INDIA-AND-BRAZIL.pdf
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