Exclusion of Certain Companies limits treaty application to holding companies and income or shares linked to them. The Agreement excludes from its scope companies enjoying special fiscal regimes in Luxembourg, specifically holding companies as defined by Luxembourg law and similar provisions enacted after signature; it also excludes income derived by a resident of India from such companies and shares or other rights in the capital of those companies owned by that resident.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Exclusion of Certain Companies limits treaty application to holding companies and income or shares linked to them.
The Agreement excludes from its scope companies enjoying special fiscal regimes in Luxembourg, specifically holding companies as defined by Luxembourg law and similar provisions enacted after signature; it also excludes income derived by a resident of India from such companies and shares or other rights in the capital of those companies owned by that resident.
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