(G) any other facility wholly owned by the Government of China, as may be agreed from time to time between the competent authorities of the States Parties; “3. Where a person other than a natural person resides in both States Parties under paragraph 1 of this article, the competent authorities of the States Parties shall designate by mutual agreement the State Party in which that person is considered to reside for the purposes of the Convention. In the absence of such a convention, that person shall not be entitled to an exemption or exemption provided for in this Convention, unless the competent authorities of the Contracting States so and in a manner agree. == 2562 (E). – The Protocol amending the Agreement between the Government of the Republic of India and the Government of the People`s Republic of China for the Avoidance of Double Taxation and the Prevention of Tax Evasion on Income, adopted on 18 signed in New Delhi, India, on 26 November 1994, in 2018, as set out in the Annex to this notification (hereinafter referred to as the “Protocol of Amendment”), ; The determination of the place of effective management, the place of creation and other relevant factors has been made mandatory by mutual agreement; In addition, the protocol contains the necessary changes to implement the minimum standards related to the contract as part of the action reports of the BASE Erosion & Profit Shifting (BEPS) project. In addition to the minimum standards, the protocol makes changes in line with the beps action reports on which the two sides have agreed, the ministry added. Under section 90 of the Income Tax Act 1961, India may enter into an agreement with a foreign country or territory to avoid double taxation of income and exchange information to prevent tax evasion. The Agreement between the Government of the Russian Federation and the Government of the Republic of Albania for the avoidance of double taxation of taxes on income and capital in accordance with the provisions of this Agreement (unless such provisions permit the taxation of India only because the income is also income of a resident resident in India) may be set off against Chinese tax, which is imposed on that resident….