Tax Treaty Modification: MLI alters applicability and timing of anti BEPS measures in a bilateral tax treaty. The MLI modifies the bilateral double tax Agreement by incorporating chosen MLI provisions into the Agreement, with authentic texts prevailing; applicability depends on each Party's MLI positions and specified commencement dates for withheld and other taxes. Article 6 of the MLI, addressing elimination of double taxation while preventing non taxation and treaty shopping, is included in the Agreement's preamble. Article 1 confirms the personal scope: the Agreement applies to persons resident in one or both Contracting States. Changes to Parties' MLI positions may alter which MLI provisions take effect.
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Provisions expressly mentioned in the judgment/order text.
Tax Treaty Modification: MLI alters applicability and timing of anti BEPS measures in a bilateral tax treaty.
The MLI modifies the bilateral double tax Agreement by incorporating chosen MLI provisions into the Agreement, with authentic texts prevailing; applicability depends on each Party's MLI positions and specified commencement dates for withheld and other taxes. Article 6 of the MLI, addressing elimination of double taxation while preventing non taxation and treaty shopping, is included in the Agreement's preamble. Article 1 confirms the personal scope: the Agreement applies to persons resident in one or both Contracting States. Changes to Parties' MLI positions may alter which MLI provisions take effect.
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