Tax treaty scope: MLI modifies the India-UK convention to prevent treaty shopping while preserving taxing rights. The synthesised text explains that the Convention between India and the United Kingdom is applied as modified by the MLI, with the authentic legal texts prevailing; it incorporates MLI provisions (including Article 6 on purpose and Article 11 limiting effects on a State's right to tax its residents) into the Convention, sets the Convention's territorial and resident scope, and states that MLI provisions take effect for the Convention on differing dates depending on the Parties' choices and the types of taxes involved.
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 scope: MLI modifies the India-UK convention to prevent treaty shopping while preserving taxing rights.
The synthesised text explains that the Convention between India and the United Kingdom is applied as modified by the MLI, with the authentic legal texts prevailing; it incorporates MLI provisions (including Article 6 on purpose and Article 11 limiting effects on a State's right to tax its residents) into the Convention, sets the Convention's territorial and resident scope, and states that MLI provisions take effect for the Convention on differing dates depending on the Parties' choices and the types of taxes involved.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 
TaxTMI 
