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.... of India and the Government of the Kingdom of Spain for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital signed on 8th February, 1993 (the "Convention"), as modified by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting signed by India and Spain on 7th June, 2017 (the "MLI"). The document was prepared on the basis of the MLI position of the India submitted to the Depositary upon ratification on 25th June, 2019 and of the MLI position of Spain submitted to the Depositary upon ratification on 28th September, 2021. These MLI positions are subject to modifications as provided in the MLI. Modifications made to MLI....

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....ences: The authentic legal 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 texts of the Convention can be found at the following link: https://www.incometaxindia.gov.in/Pages/international-taxation/dtaa.aspx https://www.boe.es/buscar/act.php?id=BOE-A-1981-15642 The MLI position of India submitted to the Depositary upon ratification on 25th June, 2019 and of the MLI position of Spain submitted to the Depositary upon ratification on 28th September, 2021 can be found on the MLI Depositary (OECD) webpage.   Entry into Ef....

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....ied with respect to taxable period beginning on or after 1st January, 2023 CONVENTION BETWEEN THE GOVERNMENT OF THE REPUBLIC OF INDIA AND THE KINGDOM OF SPAIN FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME AND ON CAPITAL The Government of the Republic of India and the Government of the Kingdom of Spain desiring to conclude a Convention for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to taxes on income and on capital have agreed as follows: The following paragraph 1 of Article 6 of the MLI is included in the preamble of this Convention: ARTICLE 6 OF THE MLI- PURPOSE OF A COVERED TAX AGREEMENT Intending to eliminate double....