Tax treaty anti BEPS purpose: India-Serbia Convention modified to prevent treaty shopping and align withholding tax application. The synthesised text integrates the Convention between India and Serbia with MLI modifications, confirms the Convention as modified applies to persons resident in one or both Contracting States, incorporates the MLI Article 6 purpose clause to prevent treaty shopping and avoidance, affirms that authentic legal texts prevail, and explains that applicability and entry into effect of specific MLI provisions depend on Parties' positions and on the tax type (withholding versus other taxes).
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Provisions expressly mentioned in the judgment/order text.
Tax treaty anti BEPS purpose: India-Serbia Convention modified to prevent treaty shopping and align withholding tax application.
The synthesised text integrates the Convention between India and Serbia with MLI modifications, confirms the Convention as modified applies to persons resident in one or both Contracting States, incorporates the MLI Article 6 purpose clause to prevent treaty shopping and avoidance, affirms that authentic legal texts prevail, and explains that applicability and entry into effect of specific MLI provisions depend on Parties' positions and on the tax type (withholding versus other taxes).
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