Tax treaty modification by MLI adjusts DTAA personal scope and timing of tax application across withholding and other taxes. The synthesised text records MLI modifications to the India-France Convention, noting that authentic MLI and Convention texts remain authoritative and that MLI provisions are incorporated in boxed insertions aligned with Convention provisions. Applicable MLI provisions take effect on differing dates depending on tax category: withholding taxes apply where the event giving rise the tax occurs on or after each State's effective date, and other taxes apply for taxable periods beginning on or after the dates specified by the States. The preamble incorporates MLI Article 6 on purpose; Article 1 confirms the Convention applies to residents.
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Provisions expressly mentioned in the judgment/order text.
Tax treaty modification by MLI adjusts DTAA personal scope and timing of tax application across withholding and other taxes.
The synthesised text records MLI modifications to the India-France Convention, noting that authentic MLI and Convention texts remain authoritative and that MLI provisions are incorporated in boxed insertions aligned with Convention provisions. Applicable MLI provisions take effect on differing dates depending on tax category: withholding taxes apply where the event giving rise the tax occurs on or after each State's effective date, and other taxes apply for taxable periods beginning on or after the dates specified by the States. The preamble incorporates MLI Article 6 on purpose; Article 1 confirms the Convention applies to residents.
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