Personal Scope

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.... the Republic of India and the Government of Canada for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital signed on 11th January, 1996 (the "Agreement"), as modified by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting signed by the India and Canada on 7th June, 2017 (the "MLI"). The document was prepared on the basis of the MLI position of India submitted to the Depositary upon ratification on 25th June, 2019 and of the MLI position of Canada submitted to the Depositary upon ratification on 29th August, 2019. These MLI positions are subject to modifications as provided in the MLI. Modifications made to MLI pos....

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....text of the MLI (in English) can be found on the MLI Depository (OECD) webpage at the following link: http://www.oecd.org/tax/treaties/multilateral-convention-to-implement-tax-treaty-related-measures-to-prevent-BEPS.pdf The authentic legal text of the Agreement (in English) can be found at the following link: https://incometaxindia.gov.in/Pages/international-taxation/dtaa.aspx The MLI position of India submitted to the Depositary upon ratification on 25th June, 2019 and of the MLI position of Canada submitted to the Depositary upon ratification on 29th August, 2019 can be found on the MLI Depositary (OECD) webpage. Entry into Effect of the MLI Provisions: The provisions of the MLI applicable to the Agreement do not take effect on t....