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..... overnment of the Republic of Latvia for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income signed on 18th September, 2013 (the Agreement ), as modified by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting signed by the India and Latvia 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 Latvia submitted to the Depositary upon approval on 29th October, 2019. These MLI positions are subject to modifications as provided in the MLI. Modifications made to MLI positions could modify the effects of t .....

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..... I Depository (OECD) webpage at the following link: http://www.oecd.org/tax/treaties/multilateral-convention-to-implement-tax-treaty-related-easures-to-prevent-BEPS.pdf The authentic legal texts of the Agreement (in English) can be found at the following link: https://www.incometaxindia.gov.in/Pages/international-taxation/dtaa.aspx https://likumi.lv/ta/id/263443-par-latvijas-republikas-valdibas-un-indijas-republikas-valdibas-ligumu-par-nodoklu-dubultas-uzliksanas-un-nodoklu-nemaksasanas The MLI position of India submitted to the Depositary upon ratification on 25th June, 2019 and of the MLI position of Latvia submitted to the Depositary upon approval on 29th October, 2019 can be found on the MLI Depositary (OECD) webpage. Entry into Effect o .....

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..... TVIA 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 Latvia, desiring to conclude an Agreement for the avoidance 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 Agreement: ARTICLE 6 OF THE MLI- PURPOSE OF A COVERED TAX AGREEMENT 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 evasion or .....

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