Dividend Transfer Transactions reservation: India limits Article 8's application where treaties provide longer minimum holding periods. India reserves Article 8's application for Covered Tax Agreements that already include a longer minimum holding period and lists an agreement (Portugal, Article 10(2)) within that reservation. India also notifies multiple bilateral treaties it considers to contain provisions corresponding to Article 8(1) that are not subject to the reservation, identifying each treaty by contracting jurisdiction and the relevant article and paragraph.
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.
Dividend Transfer Transactions reservation: India limits Article 8's application where treaties provide longer minimum holding periods.
India reserves Article 8's application for Covered Tax Agreements that already include a longer minimum holding period and lists an agreement (Portugal, Article 10(2)) within that reservation. India also notifies multiple bilateral treaties it considers to contain provisions corresponding to Article 8(1) that are not subject to the reservation, identifying each treaty by contracting jurisdiction and the relevant article and paragraph.
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