Persons Covered

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....al Evasion with respect to Taxes on Income signed on 18th May, 2015 (the "Agreement"), as modified by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting signed by the Republic of India and the Republic of Korea on 7th June, 2017 (the "MLI"). This document was prepared jointly by the Competent Authorities of the Republic of India and the Republic of Korea and represents their shared understanding of the modifications made to the Agreement by the MLI. The document was prepared on the basis of the MLI position of the Republic of India submitted to the Depositary (the Secretary-General of the Organisation for Economic Co-operation and Development) upon ratification ....

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....nce of the provisions of the MLI. In all cases, references made to the provisions of the Agreement or to the Agreement must be understood as referring to the provisions of the Agreement as modified by the provisions of the MLI, provided such provisions of the MLI have taken effect. References The authentic legal texts of the MLI can be found at the following link: http://www.oecd.org/tax/treaties/multilateral-convention-to-implement-tax-treaty-related-easures-to-prevent-BEPS.pdf The authentic legal texts of the Agreement can be found at the following link: https://www.incometaxindia.gov.in/Pages/international-taxation/dtaa.aspx http://www.law.go.kr/trtyInfoP.do?mode=4&trtySeq=12259&vSct=%EC%9D%B8%EB%8F%84 The M....

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....n or after 01st March, 2021; and ii) in the Republic of Korea: A. with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 01st January, 2021; and B. with respect to all other taxes levied by Korea, for taxes levied with respect to taxable periods beginning on or after 01st March, 2021. The Government of the Republic of India and the Government of the Republic of Korea, desiring to conclude an Agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and with a view to promoting economic cooperation between the two countries, The following preamble text describe....