Tax treaty purpose secured: MLI modifies the India-Slovak double tax agreement to prevent treaty shopping and protect taxing rights. The MLI modifies the 1986 India-Czechoslovak (Slovak Republic) double taxation Agreement by incorporating purpose and application rules: the MLI purpose clause is included in the preamble to prevent treaty shopping and ensure elimination of double taxation without enabling non taxation, and MLI Article 11 supersedes parts of the Agreement by clarifying that the Agreement does not affect a Contracting State's taxation of its residents except as to benefits granted under specified provisions as modified by the MLI. Effectivity of MLI provisions depends on each Party's choices and tax type.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Tax treaty purpose secured: MLI modifies the India-Slovak double tax agreement to prevent treaty shopping and protect taxing rights.
The MLI modifies the 1986 India-Czechoslovak (Slovak Republic) double taxation Agreement by incorporating purpose and application rules: the MLI purpose clause is included in the preamble to prevent treaty shopping and ensure elimination of double taxation without enabling non taxation, and MLI Article 11 supersedes parts of the Agreement by clarifying that the Agreement does not affect a Contracting State's taxation of its residents except as to benefits granted under specified provisions as modified by the MLI. Effectivity of MLI provisions depends on each Party's choices and tax type.
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