Tax treaty modification: MLI alters the bilateral convention to prevent treaty shopping and clarify scope of application. The synthesised text explains how the MLI modifies the India-Ukraine Convention: MLI provisions are inserted alongside Convention provisions, adapted in terminology for readability without changing substance, and apply only as reflected in the Parties' MLI positions. The document notes the authentic texts remain authoritative, that Parties' deposited positions may be modified, and that different MLI provisions take effect according to the tax type and the Parties' timing choices. It highlights insertion of the MLI purpose clause into the preamble and confirms the Convention's personal scope applies to residents of one or both Contracting States.
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Tax treaty modification: MLI alters the bilateral convention to prevent treaty shopping and clarify scope of application.
The synthesised text explains how the MLI modifies the India-Ukraine Convention: MLI provisions are inserted alongside Convention provisions, adapted in terminology for readability without changing substance, and apply only as reflected in the Parties' MLI positions. The document notes the authentic texts remain authoritative, that Parties' deposited positions may be modified, and that different MLI provisions take effect according to the tax type and the Parties' timing choices. It highlights insertion of the MLI purpose clause into the preamble and confirms the Convention's personal scope applies to residents of one or both Contracting States.
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