Tax treaty purpose: prevent double taxation while closing treaty shopping and avoidance gaps under MLI modifications to the convention. The Convention applies to persons resident in one or both Contracting States and incorporates Article 6 of the MLI as a purpose clause to eliminate double taxation while preventing non taxation and treaty shopping. The MLI modifies provisions of the Convention; those modifications take effect according to each State's MLI position and the types of taxes involved, with the authentic texts of the Convention and the MLI remaining authoritative and prevailing over the synthesised presentation.
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.
Tax treaty purpose: prevent double taxation while closing treaty shopping and avoidance gaps under MLI modifications to the convention.
The Convention applies to persons resident in one or both Contracting States and incorporates Article 6 of the MLI as a purpose clause to eliminate double taxation while preventing non taxation and treaty shopping. The MLI modifies provisions of the Convention; those modifications take effect according to each State's MLI position and the types of taxes involved, with the authentic texts of the Convention and the MLI remaining authoritative and prevailing over the synthesised presentation.
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