9911796707
TMI BlogScope of the ConventionX X X X Extracts X X X X X X X X Extracts X X X X ..... asures to Prevent Base Erosion and Profit Shifting (hereinafter referred to as the the said Convention ) was signed by India at Paris, France on the 7th day of June, 2017; And whereas, the said Convention entered into force on the 01st day of July, 2018, being the first day of month following expiration of three calendar months beginning on the date of deposit of the fifth instrument of ratificati ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the provisions of the said Convention shall have effect in India with respect to a Covered Tax Agreement in accordance with provisions of Article 35 of the said Convention; Now, therefore, in exercise of the powers conferred by sub-section (1) of section 90 of the Income-tax Act, 1961 (43 of 1961), the Central Government hereby notifies that the provisions of the said Convention shall be given ef ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... conomic activities generating the profits are carried out and where value is created; Welcoming the package of measures developed under the OECD/G20 BEPS project (hereinafter referred to as the OECD/G20 BEPS package ); Noting that the OECD/G20 BEPS package included tax treaty-related measures to address certain hybrid mismatch arrangements, prevent treaty abuse, address artificial avoidance of per ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ork of existing agreements for the avoidance of double taxation on income without the need to bilaterally renegotiate each such agreement; Have agreed as follows: PART I. SCOPE AND INTERPRETATION OF TERMS Article 1 Scope of the Convention This Convention modifies all Covered Tax Agreements as defined in subparagraph a) of paragraph 1 of Article 2 (Interpretation of Terms). - - statute, statutory ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
