Exclusion of holding companies: treaty inapplicable to privileged entities and their income or shares owned by residents.

Article 30 provides that the Agreement does not apply to holding companies as defined by Luxembourg's special fiscal laws or to other entities enjoying similar special fiscal treatment, including provisions enacted after the Agreement's signature, and that the Agreement likewise does not apply to income derived by an Indian resident from such companies or to shares or other capital rights in such companies owned by that resident.

---

---

---