Treaty anti abuse purpose: MLI modifies the India-Ireland tax convention to prevent treaty shopping and double taxation. The MLI modifies the India-Ireland Convention by adding applicable MLI provisions (including the MLI's Purpose Clause) to the Convention's text as synthesised by the Competent Authorities; authentic texts of the Convention and MLI prevail. The document explains presentation conventions, entry into effect varies by tax type and by State choices, and Article 1 (Personal Scope) provides that the Convention applies to persons resident in one or both Contracting States.
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Provisions expressly mentioned in the judgment/order text.
Treaty anti abuse purpose: MLI modifies the India-Ireland tax convention to prevent treaty shopping and double taxation.
The MLI modifies the India-Ireland Convention by adding applicable MLI provisions (including the MLI's Purpose Clause) to the Convention's text as synthesised by the Competent Authorities; authentic texts of the Convention and MLI prevail. The document explains presentation conventions, entry into effect varies by tax type and by State choices, and Article 1 (Personal Scope) provides that the Convention applies to persons resident in one or both Contracting States.
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