Multilateral Instrument modifies India-Malta tax treaty, altering applicability timing and reinforcing anti treaty shopping purpose and persons covered. The MLI modifies the India-Malta Agreement by incorporating chosen MLI provisions into the bilateral text, while preserving the authentic treaty and MLI ... Summary
Multilateral Instrument modifies India-Malta tax treaty, altering applicability timing and reinforcing anti treaty shopping purpose and persons covered.
The MLI modifies the India-Malta Agreement by incorporating chosen MLI provisions into the bilateral text, while preserving the authentic treaty and MLI texts as authoritative. Applicability of those provisions depends on each Party's reservations and notifications and may take effect on different dates for withholding taxes and for other taxes tied to taxable periods. The MLI purpose (Article 6) is included in the preamble to stress elimination of double taxation without enabling non taxation or reduced taxation through tax evasion or treaty shopping. Article 1 confirms the Agreement applies to persons resident in one or both Contracting States.
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