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..... d text for the application of the convention between the Government of the Republic of India and the Government of the Republic of Austria for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income signed on 8th November 1999 (the Convention), as modified by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting signed by the India and Austria 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 the Austria submitted to the Depositary upon ratification on 22nd September, 2017. These MLI positions ar .....

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..... ch provisions of the MLI have taken effect. References: 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 (in English) can be found at the following link: For India: https://www.incometaxindia.gov.in/Pages/international-taxation/dtaa.aspx For Austria: https://www.bmf.gv.at/steuern/int-steuerrecht/DBA-Liste.html The MLI position of the India submitted to the Depositary upon ratification on 25th June, 2019 and of the MLI position of the Austria submitted to the Depositary upon ratification on 22nd September, 2017 .....

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..... OVERNMENT OF THE REPUBLIC OF INDIA AND THE GOVERNMENT OF THE REPUBLIC OF AUSTRIA FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME The Government of the Republic of India and the Government of the Republic of Austria, desiring to conclude a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, 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 taxation with respect to the taxes covered by this [1] Convention without creating opportunities for non-taxation or reduced taxation through tax eva .....

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