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..... public of India and the Government of Malta for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income signed on 8th April, 2013 (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 Malta 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 Malta submitted to the Depositary upon ratification on 18th December, 2018. These MLI positions are subject to modifications as provided in the MLI. Modifications made to MLI positions could modify the effects of .....

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..... 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: - In India at the following link: https://www.incometaxindia.gov.in/Pages/international-taxation/dtaa.aspx - In Malta at the following link: http://www.justiceservices.gov.mt/DownloadDocument.aspx?app=lom itemid=9342 l=1 The MLI position of India submitted to the Depositary upon ratification on 25th June, 2019 and of the MLI position of Malta submitted to the Depositary upon ratification on 18th December, 2018 can be found on the MLI Depositary (OECD) webpage. Disclaimer on the Entry into Effect of the M .....

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..... E PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME The Government of the Republic of India and the Government of Malta, 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 avoidance (including through treaty-shopping arrangements aimed a .....

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