Tax treaty modification limits application of treaty benefits to prevent treaty shopping and clarifies entry into force timelines. The MLI amends the India-Russia Double Taxation Agreement by incorporating MLI provisions (including Article 6 on purpose) and applying paragraph 1 of Article 11 to limit how the Agreement affects a Contracting State's taxation of its residents, subject to specified treaty benefits and referenced MLI modifications. The synthesis records Competent Authorities' positions, confirms that authentic texts prevail, and sets differing entry into effect dates for withholding and other taxes based on ratification notifications and parties' MLI choices.
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Tax treaty modification limits application of treaty benefits to prevent treaty shopping and clarifies entry into force timelines.
The MLI amends the India-Russia Double Taxation Agreement by incorporating MLI provisions (including Article 6 on purpose) and applying paragraph 1 of Article 11 to limit how the Agreement affects a Contracting State's taxation of its residents, subject to specified treaty benefits and referenced MLI modifications. The synthesis records Competent Authorities' positions, confirms that authentic texts prevail, and sets differing entry into effect dates for withholding and other taxes based on ratification notifications and parties' MLI choices.
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