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TMI BlogAligning purpose of entering into Double Taxation Avoidance Agreements (DTAA) with Multilateral Instrument (MLI).X X X X Extracts X X X X X X X X Extracts X X X X ..... l Government to enter into agreement with foreign countries or specified territories (commonly known as DTAAs) for,- (a) granting relief in respect of - (i) income on which tax has been paid both, in India and that foreign country or territory, or (ii) income-tax chargeable under the laws of both, India and that foreign country or territory, to promote mutual economic relations, trade and in ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tax. India has signed the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (commonly referred to as MLI) along with representatives of many countries, which has since been ratified. India has since deposited the Instrument of Ratification to OECD, Paris along with its Final Position in terms of Covered Tax Agreements (CTAs), Reservations ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... be applied alongside existing DTAAs, modifying their application in order to implement the BEPS measures. Article 6 of MLI provides for modification of the Covered Tax Agreement to include the following preamble text: "Intending to eliminate double taxation with respect to the taxes covered by this agreement without creating opportunities for non-taxation or reduced taxation through tax evasi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... vernment of any country outside India or specified territory outside India for, inter alia, the avoidance of double taxation of income under the Act and under the corresponding law in force in that country or specified territory, as the case may be, without creating opportunities for non-taxation or reduced taxation through tax evasion or avoidance (including through treaty-shopping arrangements a ..... X X X X Extracts X X X X X X X X Extracts X X X X
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