Elimination of double taxation through an MLI modified treaty seeks to prevent treaty shopping and tax avoidance practices. The synthesized text explains that the MLI modifies the India-Austria Convention, that applicable MLI provisions are those elected by the Parties and may take effect on differing dates depending on tax type and Party choices, and that Article 1 of the Convention operates to apply the Convention to persons who are residents of one or both Contracting States; textual adjustments in the synthesis are for readability and do not change substance.
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.
Elimination of double taxation through an MLI modified treaty seeks to prevent treaty shopping and tax avoidance practices.
The synthesized text explains that the MLI modifies the India-Austria Convention, that applicable MLI provisions are those elected by the Parties and may take effect on differing dates depending on tax type and Party choices, and that Article 1 of the Convention operates to apply the Convention to persons who are residents of one or both Contracting States; textual adjustments in the synthesis are for readability and do not change substance.
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