“In line with India`s policy on the taxation of capital gains on shares, the revised DBAA provides for source-based taxation on capital gains resulting from the disposal of shares representing more than 5% of the share capital.” “These return requests shall be processed in accordance with the provisions of the Income Tax Act and the applicable I-T rules. The inclusion of the return provision in such bilateral ABS would also be subject to the rules in force in Korea,” the CBDT said. 4. The competent authorities of the Contracting States may communicate directly with each other with a view to reaching an agreement within the meaning of the above paragraphs. In addition to income tax treaties aimed at avoiding double taxation, Korea has concluded TIEAs with many countries, including some tax havens and those that have provisionally concluded such agreements. TIEA coverage extends to Andorra, Bermuda, the British Virgin Islands and the Cook Islands, to name a few. TIEAs include information necessary for the management and enforcement of national tax law, including details relating to the registration of taxpayers, details relating to the ownership of the business, accounting documents and financial statements of a given business transaction, as well as information about financial transactions carried out by individuals or companies. TIEAS creates a framework for Korea to limit abusive tax evasion transactions in tax havens, establish and collect taxes on offshore tax evasion transactions. . . .