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..... ent of the Republic of India and the Government of the Grand Duchy of Luxembourg for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on capital signed on 2nd June, 2008 (the Agreement ), as modified by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting signed by India and Luxembourg 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 Luxembourg submitted to the Depositary upon ratification on 9th April, 2019. These MLI positions are subject to modifications as provided in the MLI. Modifi .....

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..... 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-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 impotsdirects.public.lu The MLI position of India submitted to the Depositary upon ratification on 25th June, 2019 and of the MLI position of Luxembourg submitted to the Depositary upon ratification on 9th April, 2019 can be found on the MLI Depositary (OECD) webpage. Entry into Effect of the MLI Provisions: The provisions of the MLI applicable to the Agree .....

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..... H RESPECT TO TAXES ON INCOME AND ON CAPITAL The Government of the Republic of India and the Government of the Grand Duchy of Luxembourg, desiring to conclude an Agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital 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 avoidance (including through treaty-shopping .....

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