Tax treaty modification clarifies MLI application to India-Spain DTAA and specifies phased entry and scope rules. The MLI modifies the India-Spain Convention by mapping MLI provisions onto the treaty, preserving the authentic texts as authoritative. Applicability varies by tax type and by each State's MLI position; phased entry into effect applies differently for withholding taxes and other taxes. Changes to MLI positions can alter effects on the Convention. Article 1 confirms the Convention's Personal Scope as applying to residents of one or both Contracting States, and the MLI purpose on preventing treaty shopping is included in the preamble.
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Tax treaty modification clarifies MLI application to India-Spain DTAA and specifies phased entry and scope rules.
The MLI modifies the India-Spain Convention by mapping MLI provisions onto the treaty, preserving the authentic texts as authoritative. Applicability varies by tax type and by each State's MLI position; phased entry into effect applies differently for withholding taxes and other taxes. Changes to MLI positions can alter effects on the Convention. Article 1 confirms the Convention's Personal Scope as applying to residents of one or both Contracting States, and the MLI purpose on preventing treaty shopping is included in the preamble.
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