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TMI BlogPersonal ScopeX X X X Extracts X X X X X X X X Extracts X X X X ..... overnment of the Republic of India and the Government of the Czechoslovak Socialist Republic (which applies to the Slovak Republic, being one of the independent states to have succeeded the Czechoslovak Socialist Republic) for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income signed on 27th January, 1986 (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 the Slovak Republic 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 Slov ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... understood as referring to the Agreement as modified by the provisions 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-measures-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 The MLI position of the India submitted to the Depositary upon ratification on 25th June, 2019 and of the MLI position of the Slovak Republic submitted to the Depositary upon ratification on 20t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME The Government of India and the Government of the Czechoslovak Socialist Republic, Desiring to conclude an agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, 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 at obtaining reliefs provided in ..... X X X X Extracts X X X X X X X X Extracts X X X X
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