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TMI BlogPersonal ScopeX X X X Extracts X X X X X X X X Extracts X X X X ..... the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income signed on 3rd November, 2003 (the Convention ), as modified by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting signed by India and Hungary on 7th June, 2017 (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 of the MLI position of Hungary submitted to the Depositary upon ratification on 25th March, 2021. These MLI positions are subject to modifications as provided in the MLI. Modifications made to MLI positions could modify the effects of the MLI on this Convention. The authentic ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t 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: In India: https://www.incometaxindia.gov.in/Pages/international-taxation/dtaa.aspx - In Hungary: https://njt.hu/jogszabaly/2005-144-00-00 The MLI position of India submitted to the Depositary upon ratification on 25th June, 2019 and the MLI position of Hungary submitted to the Depositary upon ratification on 25th March, 2021 can be found on the MLI Depositary (OECD) webpage. Entry into Effect of the MLI Provisions: The provisions of the MLI applicable to the Convention do not take effect on the same dates as the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e of double taxation and the prevention of fiscal evasion with respect to taxes on income and with a view to promoting economic cooperation between the two countries, 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 evasion or avoidance (including through treaty-shopping arrangements aimed at obtaining reliefs provided in this [Convention] for the indirect benefit of residents of third jurisdictions), have agreed as follows: ARTICLE 1 PERSONAL SCOPE This Conventio ..... X X X X Extracts X X X X X X X X Extracts X X X X
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