Reservation under Article 3: India excludes application of Article 3 to its covered tax agreements under BEPS treaty measures. India has declared a reservation permitting the non-application of Article 3 in its entirety to its covered tax agreements, thereby excluding the Convention's rules on the status and treatment of transparent entities from applying to those agreements and preserving India's existing treatment of such entities within its covered tax agreements.
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.
Reservation under Article 3: India excludes application of Article 3 to its covered tax agreements under BEPS treaty measures.
India has declared a reservation permitting the non-application of Article 3 in its entirety to its covered tax agreements, thereby excluding the Convention's rules on the status and treatment of transparent entities from applying to those agreements and preserving India's existing treatment of such entities within its covered tax agreements.
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