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..... ention between the Government of the Republic of India and the Kingdom of Netherlands for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on capital signed on 30th July, 1988 and amended by the Amending Protocol signed on 10th May, 2012 (the Convention ), as modified by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting signed by the India and Netherlands on 7th June, 2017 (the MLI ). The document was prepared on the basis of the MLI position of the India submitted to the Depositary upon ratification on 25th June, 2019 and of the MLI position of the Netherlands submitted to the Depositary upon ratification on 29th March, 2 .....

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..... ons of the MLI, provided such provisions of the MLI have taken effect. References: The authentic 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 Convention (in English) can be found in India at the following link: https://www.incometaxindia.gov.in/Pages/international-taxation/dtaa.aspx The MLI position of the India submitted to the Depositary upon ratification on 25th June, 2019 and of the MLI position of the Netherlands submitted to the Depositary upon ratification on 29th March, 2019 can be found on the MLI Depositary (OECD) webpage .....

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..... TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME AND ON CAPITAL The Government of the Republic of India and the Government of the Kingdom of Netherlands. Desiring to conclude a convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital: T he 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 o .....

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