3. The competent authorities of the contracting states try to resolve by mutual agreement any difficulty or doubt about the interpretation or application of the convention. They can also work together to eliminate double taxation in cases not included in this agreement. Income Tax Act 1961: Section 90 communication: Agreement between the Government of the Republic of India and the Government of the People`s Republic of China to avoid double taxation and prevent tax evasion with respect to income taxes 3. This Convention does not affect the taxation of its residents by a State Party, unless the benefits granted to it under Article 9, paragraph 2, second paragraph, and Article 19, 20, 21, 23, 24, 25 and 27 apply. BEPS are tax evasion strategies that exploit loopholes and discrepancies in the tax rules of different countries to artificially transfer profits from regions with higher tax regimes to countries with lower taxes. The 2012 G20 summit instructed the OECD to set minimum standards to prevent such tax evasion. Under Section 90 of the Income-tax Act 1961, India can enter into an agreement with a foreign country or a specific territory to avoid double taxation of income, to exchange information on the prevention of tax evasion. The competent authorities of the contracting states inform each other of any substantial changes to their tax legislation within a reasonable time after these changes. The determination of the place of effective management, the place of creation and these other relevant factors was made mandatory by mutual agreement; and two. The competent authority endeavours to resolve the matter by mutual agreement with the competent authority of the other State party if the objection appears to be well founded and does not itself reach a satisfactory solution to settle the matter by mutual agreement with the competent authority of the other contracting State, in order to avoid an imposition that is not in accordance with the provisions of this agreement. Any agreement reached will be implemented in the domestic law of the States Parties, regardless of the time frame.