Article 8 - Dividend Transfer Transactions - France - Convention to Implement Tax Treaty related Measures to Prevent Base Erosion and Profit Shifting

Article 8 Dividend Transfer Transactions Reservation Pursuant to Article 8(3)(b)(iii) of the Convention, India reserves the right for the entirety of Article 8 not to apply to its Covered Tax Agreements to the extent that the provisions described in Article 8(1) already include a minimum holding period longer than a 365 day period. The following agreement contains provisions that are within the scope of this reservation. Listed Agreement Number Other Contracting Jurisdiction Provision 63 Portugal Article 10(2) Notification of Existing Provisions in Listed Agreements Pursuant to Article 8(4) of the Convention, India considers that the following agreements contain a provision described in Article 8(1) that is not subject to a reservation described in Article 8(3)(b). The article and paragraph number of each such provision is identified below . Listed Agreement Number Other Contracting Jurisdiction Provision 5 Bangladesh Article 11(2)(a) 6 Belarus Article 10(2)(a) 9 Botswana Article 10(2)(a) 12 Canada Article 10(2)(a) 14 Croatia Article 10(2)(a) 17 Denmark Article 11(2)(a) 33 Italy Article 11(2)(a) 43 Lithuania Article 10(2)(a) 48 Mauritius Article 10(2)(a) 51 Montenegro Article 10(2)(1) 56 Nepal Article 10(2)(a) 60 Oman Article 11(2)(a) 61 Philippines Article 11(2)(a) 64 Qatar Article 10(2)(a) 68 Serbia Article 10(2)(1) 69 Singapore Article 10(2)(a) 70 Slovak Republic Article 10(2)(a) 71 Slovenia Article 10(2)(a) 78 Syria Article 10(2)(a) 79 Tajikistan Article 10(2)(a) 80 Tanzania Article 10(2)(a) 86 Ukraine Article 10(2)(a) 90 USA Article 10(2)(a) 93 Zambia Article 10(2)(a)