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. According to the OECD7, “income earned by or by an entity or agreement considered to be fully or partially tax-transparent under the tax legislation of one of the two contracting states” must also be considered “income of a resident of a contracting state,” but only to the extent that income is processed for taxation by that state. , as income from a state established in that state. The existing tax treaty between India and Brazil will be amended to bring it in line with international developments and to implement the recommendations of the G20 OECD Base Erosion and Profit Shifting Project (BEPS), as Brazil has decided not to sign the multilateral agreement on the implementation of tax convention measures to prevent BEPS (MLI). 4.

The term “interest” used in this article refers to income from government bonds, bonds or bonds, whether or not they are secured by mortgages, whether or not they have the right to participate in profits, as well as receivables of any kind, as well as other income from the income of the contracting state in which the income is generated.