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 ... Summary
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.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.