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of <h1>India-France Pact: Article 16 on Mutual Agreement Procedure in DTAA Tackles Base Erosion, Profit Shifting, and Dispute Resolution</h1> Article 16 of the Convention between India and France addresses the Mutual Agreement Procedure (MAP) under the Double Tax Avoidance Agreement (DTAA) framework, aimed at preventing base erosion and profit shifting. India reserves the right not to apply the first sentence of Article 16(1) to its Covered Tax Agreements, ensuring dispute resolution through competent authorities regardless of domestic remedies. The document lists agreements with specific time periods for presenting cases, distinguishing between those with periods shorter or longer than three years. Additionally, it identifies agreements lacking provisions as described in certain sub-articles of Article 16.
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