Tax treaty modification under the MLI alters application and entry into effect of the DTAA, affecting withholding and other taxes. The MLI modifies the India-Estonia Agreement by incorporating selected MLI provisions into the bilateral DTAA with editorial terminology adjustments, while preserving the authentic texts as authoritative. Applicability of MLI changes depends on Parties' notified choices and differs for withholding taxes versus other taxes, with temporal application governed by Article 35 mechanics and the Parties' ratification and entry into force positions. The Agreement's domestic implementation in India is recorded, and Article 1 covers residents of one or both Contracting States; the preamble includes paragraph 1 of MLI Article 6 on preventing treaty shopping and non taxation.
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Provisions expressly mentioned in the judgment/order text.
Tax treaty modification under the MLI alters application and entry into effect of the DTAA, affecting withholding and other taxes.
The MLI modifies the India-Estonia Agreement by incorporating selected MLI provisions into the bilateral DTAA with editorial terminology adjustments, while preserving the authentic texts as authoritative. Applicability of MLI changes depends on Parties' notified choices and differs for withholding taxes versus other taxes, with temporal application governed by Article 35 mechanics and the Parties' ratification and entry into force positions. The Agreement's domestic implementation in India is recorded, and Article 1 covers residents of one or both Contracting States; the preamble includes paragraph 1 of MLI Article 6 on preventing treaty shopping and non taxation.
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