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..... dia and the Government of Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and Capital Gains signed on 6th November, 2000 (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 by Ireland 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 the MLI position of Ireland submitted to the Depositary upon ratification on 29th January, 2019. These MLI positions are subject to modifications as provided in the MLI. Modifications made to MLI positions could modify .....

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..... lish) 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: In India: https://www.incometaxindia.gov.in/Pages/international-taxation/dtaa.aspx In Ireland: http://www.irishstatutebook.ie/eli/2018/si/440/made/en/print http://www.irishstatutebook.ie/eli/2001/si/521/made/en/print The MLI position of India submitted to the Depositary upon ratification on 25th June, 2019 and the MLI position of Ireland submitted to the Depositary upon ratification on 29th January, 2019 can be found on the MLI Depositary (OECD) webpage. E .....

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..... PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME AND CAPITAL GAINS The Government of the Republic of India and the Government of Ireland, desiring to conclude a Convention for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to taxes on income and capital gains and with a view to promoting economic co-operation 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 t .....

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