Tax treaty modification: MLI alters application timing and anti-treaty shopping purpose of the India-Finland tax Agreement. The document explains how the MLI modifies the India-Finland tax Agreement, noting authentic texts remain authoritative, MLI positions and a Finnish withdrawal of a reservation, and that MLI provisions apply on differing dates depending on tax type and each State's positions. It records deposit and entry-into-force dates, the effective dates for withholding and other taxes (including staggered effect for Article 9(4)), and confirms Article 1 of the Agreement applies to persons who are residents of one or both Contracting States while the MLI preamble adds a purpose to prevent treaty-shopping and non taxation.
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Tax treaty modification: MLI alters application timing and anti-treaty shopping purpose of the India-Finland tax Agreement.
The document explains how the MLI modifies the India-Finland tax Agreement, noting authentic texts remain authoritative, MLI positions and a Finnish withdrawal of a reservation, and that MLI provisions apply on differing dates depending on tax type and each State's positions. It records deposit and entry-into-force dates, the effective dates for withholding and other taxes (including staggered effect for Article 9(4)), and confirms Article 1 of the Agreement applies to persons who are residents of one or both Contracting States while the MLI preamble adds a purpose to prevent treaty-shopping and non taxation.
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