Decree 510, issued on 28 April 1992, contains the text of the bilateral income tax agreement signed by Brazil and India (“treaty”). The treaty aims to prevent cross-border transactions between the two countries from being subject to double income taxes rather than income tax. 1. Nationals of a contracting state must not be subject to a different or heavier taxation or requirement in the other contracting state than the imposition and related requirements to which nationals of that other state are subject or may be subject in the same circumstances. Article 11. For interpretation, international conventions and conventions to avoid double taxation are signed by the Government of the Federal Republic of Brazil. In an official press release, it was stated that the repeal of the provisions of the Convention on the Prevention of Double Taxation (DTAC) to international standards, the protocol of amendment between India and the Federal Republic of Brazil would facilitate the elimination of double taxation. 3. The term “dividends” used in this article refers to income from shares, “enjoyment” or “enjoyment” rights, mining shares, incubating shares or other rights other than debts participating in profits, as well as income from other corporate rights which, according to the laws of the state of which the resident company is steep, are subject to the same tax treatment as the shares. 1. The competent authorities of the contracting states exchange the information (including documents) necessary for the implementation of the provisions of the Convention or national legislation of the contracting states relating to the taxes covered by the Convention, as long as the imposition of the convention is not contrary to the convention, in particular to prevent fraud or fraud. All information received from a State Party is considered secret, such as information obtained under the state`s national law. However, if the information is initially considered secret in the state that transmits it, it is disclosed only to persons or authorities (including courts and administrative authorities) who participate in the assessment or collection, execution or prosecution, or determination of the remedies relating to the taxes that are the subject of the agreement.

These persons or authorities may only use this information for such purposes, but they may disclose it in the context of a public judicial proceeding or a judicial decision. The relevant authorities develop appropriate conditions, methods and techniques for information exchange issues, including, where appropriate, the exchange of information on tax evasion, through consultations.