MLI application alters DTAA provisions to prevent treaty shopping while preserving the Agreement and MLI as authoritative texts. The MLI modifies the India-Singapore Agreement where Parties' MLI positions apply, while the authentic texts of the Agreement and the MLI remain authoritative. The Agreement's personal scope covers residents of one or both Contracting States and incorporates the MLI preambular aim to eliminate double taxation without creating treaty shopping opportunities. Application timing and tax type distinctions determine when specific MLI provisions affect the Agreement, and changes to Parties' MLI positions may alter those effects.
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Provisions expressly mentioned in the judgment/order text.
MLI application alters DTAA provisions to prevent treaty shopping while preserving the Agreement and MLI as authoritative texts.
The MLI modifies the India-Singapore Agreement where Parties' MLI positions apply, while the authentic texts of the Agreement and the MLI remain authoritative. The Agreement's personal scope covers residents of one or both Contracting States and incorporates the MLI preambular aim to eliminate double taxation without creating treaty shopping opportunities. Application timing and tax type distinctions determine when specific MLI provisions affect the Agreement, and changes to Parties' MLI positions may alter those effects.
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