Tax treaty modification under the MLI alters applicability of the India-Luxembourg DTAA, affecting residents' tax coverage. The MLI modifies the India-Luxembourg Agreement to implement measures preventing base erosion and profit shifting, incorporating selected MLI provisions into the Agreement while preserving the authentic texts as authoritative; MLI effects vary by provision and by tax type (withholding versus other taxes) according to the parties' positions and entry-into-effect rules. Article 1, as modified, applies the Agreement to persons who are residents of one or both Contracting States, and the MLI purpose clause addressing elimination of double taxation without enabling treaty-shopping is included in the preamble.
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Tax treaty modification under the MLI alters applicability of the India-Luxembourg DTAA, affecting residents' tax coverage.
The MLI modifies the India-Luxembourg Agreement to implement measures preventing base erosion and profit shifting, incorporating selected MLI provisions into the Agreement while preserving the authentic texts as authoritative; MLI effects vary by provision and by tax type (withholding versus other taxes) according to the parties' positions and entry-into-effect rules. Article 1, as modified, applies the Agreement to persons who are residents of one or both Contracting States, and the MLI purpose clause addressing elimination of double taxation without enabling treaty-shopping is included in the preamble.
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