Tax treaty anti abuse purpose: MLI modified India-Iceland DTAA aligns provisions to prevent treaty shopping and base erosion. The MLI modifies the India-Iceland Agreement by integrating selectable MLI provisions into the treaty text while preserving the authentic legal texts; MLI provisions apply to the Agreement only as and when the Parties' specified choices take effect, with temporal distinctions between withholding taxes and other taxes. The synthesis incorporates the MLI purpose clause to prevent treaty shopping and confirms that Article 1 of the Agreement covers persons resident in one or both Contracting States.
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Provisions expressly mentioned in the judgment/order text.
Tax treaty anti abuse purpose: MLI modified India-Iceland DTAA aligns provisions to prevent treaty shopping and base erosion.
The MLI modifies the India-Iceland Agreement by integrating selectable MLI provisions into the treaty text while preserving the authentic legal texts; MLI provisions apply to the Agreement only as and when the Parties' specified choices take effect, with temporal distinctions between withholding taxes and other taxes. The synthesis incorporates the MLI purpose clause to prevent treaty shopping and confirms that Article 1 of the Agreement covers persons resident in one or both Contracting States.
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