Dual resident entities rule confirms treaty tie breaker application, listing covered agreements and specified jurisdictional deviations.

India notifies, under the BEPS Convention, that specified bilateral tax agreements contain a dual resident entities tie breaker provision corresponding to Article 4(2) and not subject to Article 4(3)(b)-(d) reservations. The notification lists each contracting jurisdiction and the particular Article 4 paragraph relied on; most are Article 4(3), while Japan is recorded as Article 4(2), Kuwait and United Arab Emirates as Article 4(4), and the United States as Article 4(3) and (4).

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