This agreement does not affect the tax privileges of members of diplomatic or consular missions, in accordance with the general rules of international law or the provisions of specific agreements. 1. The competent authorities of the contracting states exchange the information (including documents or certified copies of the documents) necessary for the implementation of the provisions of this agreement or for the management or application of national tax legislation of any kind and description imposed on behalf of the contracting states or their political sub-divisions or communities. , to the extent that the provisions of the agreement are not contrary to the convention. The exchange of information is not limited by Articles 1 and 2. 1. Legislation in force in none of the contracting states continues to govern the taxation of income in the contracting states concerned, unless this agreement provides for contrary provisions. The revised DBAA will improve tax transparency, help reduce tax evasion and evasion, eliminate double taxation and stimulate the flow of investment, technology and services between India and Kenya. 3. The term “dividends” used in this article refers to income from shares or other rights that are not claims that contribute to profits, as well as income from other rights of corporations subject to the same tax treatment as share income, under the law of the state in which the company is established. (2) However, these dividends may also be taxed in the contracting state in which the resident company is established and according to the law of that state, but if the actual beneficiary of the dividends is established in the other contracting state, the tax thus collected cannot exceed 10% of the gross amount of the dividends. This paragraph does not affect the corporation`s taxation on the profits on which the dividends are paid. 4.
The agreement also applies to all identical or essentially similar taxes levied after the date of the signing of the agreement, in addition to or in place of existing taxes. The competent authorities of the contracting states inform each other of any substantial changes to their respective tax laws. (4) Companies of a contracting state whose capital is directly or indirectly owned by one or more residents of the other contracting state or who are subject to a tax or related requirement may not be subject, in the first country, to a tax or related requirement that is different or more burdensome than the taxation and related requirements. other similar enterprises in the first state are or may be subject to.