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of <h1>India Reserves Right to Exclude Article 8 from DTAA on Dividend Transfers for Certain Agreements with Long Holding Periods</h1> Article 8 of the Convention addresses Dividend Transfer Transactions under the Double Tax Avoidance Agreement (DTAA) between India and France, aiming to prevent base erosion and profit shifting. India reserves the right not to apply Article 8 to its Covered Tax Agreements if they already include a minimum holding period exceeding 365 days, as seen in its agreement with Portugal. Additionally, India identifies agreements with other jurisdictions, such as Bangladesh, Belarus, and the USA, which contain provisions aligned with Article 8(1) and are not subject to the reservation. These agreements specify particular articles and paragraphs where these provisions are applicable.
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