https://www.taxtmi.com/caselaws?id=466308 Most Favoured Nation treatment under the India-Netherlands DTAA Protocol requires that the subsequently relied-on treaty partner was an OECD member when its treaty with India entered into force and that India has notified the imported treaty benefit under the Income-tax Act. Slovenia was not an OECD member when its treaty entered into force, and no notification imported its dividend-rate benefit into the Netherlands treaty. The Protocol reference therefore did not independently permit application of the lower 5% dividend tax rate; dividends remained taxable at the 10% treaty rate. en-us Fri, 28 Feb 2025 00:00:00 +0530 Sun, 01 Feb 2026 19:07:20 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=466308 Most Favoured Nation treatment under the India-Netherlands DTAA Protocol requires that the subsequently relied-on treaty partner was an OECD member when its treaty with India entered into force and that India has notified the imported treaty benefit under the Income-tax Act. Slovenia was not an OECD member when its treaty entered into force, and no notification imported its dividend-rate benefit into the Netherlands treaty. The Protocol reference therefore did not independently permit application of the lower 5% dividend tax rate; dividends remained taxable at the 10% treaty rate. Case-Laws Income Tax Fri, 28 Feb 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=466308