The notification amends the treaty by incorporating anti-abuse measures, including a revised preamble, Principal Purpose Test, and Limitation of Benefits provisions to curb treaty shopping and tax evasion. It expands definitions (e.g., resident, permanent establishment), introduces rules for service PEs, and refines taxation of dividends, interest, royalties, and fees for technical services with specified withholding tax caps. It also updates provisions on capital gains, employment income, and dispute resolution.
