Personal Scope

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.... respect to Taxes on Income signed on 24th January, 1994, as amended by the Protocols signed on 29th June, 2005, 24th June, 2011 and 30th December, 2016 respectively (hereinafter referred to as the "Agreement"), as modified by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting signed by India and Singapore on 7th June, 2017 (the "MLI"). The document was prepared on the basis of the MLI position of India submitted to the Depositary (the Secretary-General of the Organisation for Economic Co-operation and Development) upon ratification on 25th June, 2019 and of the MLI position of Singapore submitted to the Depositary upon ratification on 21st December, 2018. Th....

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....and are not intended to change the substance of the provisions of the MLI. Unless the context otherwise requires, references made to the provisions of the Agreement will be understood as referring to the provisions of the Agreement as modified by the provisions of the MLI. References The text 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 text of the Agreement can be found at the following link: https://www.incometaxindia.gov.in/Pages/international-taxation/dtaa.aspx For the Republic of Singapore: on the Singapore Statutes Online website (https://sso.agc.gov.sg) The MLI position of India submitted to the Deposita....