MLI modifications to a bilateral tax convention clarify treaty scope and restrict treaty-shopping and timing. This explanatory synthesis describes how the Multilateral Instrument modifies the Convention between India and Portugal: it is non-authoritative, adapts MLI terminology for readability without changing substance, and makes application dependent on each State's reservations and notifications. It notes inclusion of the MLI Article 6 preamble on preventing treaty-shopping and application of Article 11(1) preserving taxation of residents except as specifically limited by certain Convention provisions. The effective dates of MLI provisions vary by tax type and by each State's entry into effect.
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.
MLI modifications to a bilateral tax convention clarify treaty scope and restrict treaty-shopping and timing.
This explanatory synthesis describes how the Multilateral Instrument modifies the Convention between India and Portugal: it is non-authoritative, adapts MLI terminology for readability without changing substance, and makes application dependent on each State's reservations and notifications. It notes inclusion of the MLI Article 6 preamble on preventing treaty-shopping and application of Article 11(1) preserving taxation of residents except as specifically limited by certain Convention provisions. The effective dates of MLI provisions vary by tax type and by each State's entry into effect.
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