9911796707
TMI BlogPersonal ScopeX X X X Extracts X X X X X X X X Extracts X X X X ..... ederation for the Avoidance of Double Taxation with respect to Taxes on Income signed on 25th March, 1997 (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 Russian Federation ( Russia ) 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 Russia submitted to the Depositary upon ratification on 18th June, 2019. These MLI positions are subject to modifications as provided in the MLI. Modifications made to MLI positions could modify the effects of the MLI on the Agreement. The authen ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ollowing 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 http://www.minfin.ru/ru/perfomance/tax_relations/international/?id_57=124786 area_id=57 page_id=179 popup=Y The MLI position of the India submitted to the Depositary upon ratification on 25th June, 2019 and the MLI position of the Russian Federation submitted to the Depositary upon ratification on 18th June, 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 Ag ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... six calendar months from 30 days after the date of receipt (which is 30-4-2020) by the Depositary of the latest notification by the Russian Federation making the reservation described in paragraph 7 of Article 35 (Entry into Effect) that it has completed its internal procedures for the entry into effect of the provisions of the MLI with respect to the Agreement. In Russia: ➢ With respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1-1-2021 i.e. the first day of the next calendar year that begins on or after 30 days after the date of receipt (which is 30-4-2020) by the Depositary of the latest notification by the Russian Federation making the r ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... portunities for non-taxation or reduced taxation through tax evasion or avoidance (including through treaty-shopping arrangements aimed at obtaining reliefs provided in this Agreement for the indirect benefit of residents of third jurisdictions), have agreed as follows: ARTICLE 1 PERSONAL SCOPE This Agreement shall apply to persons who are residents of one or both of the Contracting States. The following paragraph 1 of Article 11 of the MLI applies and supersedes the provisions of this Agreement: ARTICLE 11 OF THE MLI- APPLICATION OF TAX AGREEMENTS TO RESTRICT A PARTY'S RIGHT TO TAX ITS OWN RESIDENTS [ The Agreement ] shall not affect the taxation by a [1] [ Contracting State ] of its residents, except with respect to the benefits grant ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
