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....tenegro (which applies to the Republic of Serbia) for the Avoidance of Double Taxation with respect to Taxes on Income and on Capital signed on 8th February 2006 (the "Convention"), 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 (India) and the Republic of Serbia (Serbia) on 7th June 2017 (the "MLI"). This document was prepared jointly by the competent authorities of India and Serbia and represents their shared understanding of the modifications made to the Convention by 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 MLI positi....

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.... the Convention must be understood as referring to the Convention as modified by the provisions of the MLI, provided such provisions of the MLI have taken effect. References The authentic legal text of the MLI can be found on the MLI Depositary (OECD) webpage: • in English: https://www.oecd.org/tax/treaties/multilateral-convention-to-implement-tax-treaty-related- easures-to-prevent-BEPS.pdf ; and • in French: http://www.oecd.org/fr/fiscalite/conventions/convention-multilaterale-pour-la-mise-en-oeuvre-des-mesures-relatives-aux-conventions-fiscales-pour-prevenir-le-BEPS.pdf. The authentic legal text of the Convention (in English) can be found at the following link: https://www.incometaxindia.gov.in/....

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.... taxable periods beginning on or after 1 April 2020; and • With respect to all other taxes levied by Serbia, for taxes levied with respect to taxable periods beginning on or after 1 April 2020. CONVENTION BETWEEN THE GOVERNMENT OF THE REPUBLIC OF INDIA AND THE COUNCIL OF MINISTERS OF SERBIA AND MONTENEGRO FOR THE AVOIDANCE OF DOUBLE TAXATION WITH RESPECT TO TAXES ON INCOME AND ON CAPITAL THE GOVERNMENT OF THE REPUBLIC OF INDIA AND THE COUNCIL OF MINISTERS OF SERBIA AND MONTENEGRO desiring to conclude a Convention for the avoidance of double taxation with respect to taxes on income and on capital and with a view to promoting economic cooperation between the two countries, The following paragraph ....