Purpose of covered tax agreement: eliminate double taxation while preventing tax avoidance and treaty shopping. The synthesised text records that the MLI modifies the India-Georgia Agreement by incorporating applicable MLI provisions into the Agreement as modified, with authentic texts prevailing; temporal application varies by provision and tax type; the Agreement applies to persons resident in one or both Contracting States; the preamble adopts Article 6(1) of the MLI, stating the Agreement's purpose to eliminate double taxation while preventing non taxation or reduced taxation through evasion, avoidance, and treaty shopping.
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Provisions expressly mentioned in the judgment/order text.
Purpose of covered tax agreement: eliminate double taxation while preventing tax avoidance and treaty shopping.
The synthesised text records that the MLI modifies the India-Georgia Agreement by incorporating applicable MLI provisions into the Agreement as modified, with authentic texts prevailing; temporal application varies by provision and tax type; the Agreement applies to persons resident in one or both Contracting States; the preamble adopts Article 6(1) of the MLI, stating the Agreement's purpose to eliminate double taxation while preventing non taxation or reduced taxation through evasion, avoidance, and treaty shopping.
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