Scope of the Convention

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..... apital Gains signed on 25 January 1993 and the Protocol signed on 30 October 2012 (together the Convention ), as modified by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting signed by the Republic of India and the United Kingdom on 7 June 2017 (the MLI ). This document was prepared jointly by the competent authorities of the Republic of India and the United Kingdom and represents their shared understanding of the modifications made to the Convention by the MLI. The document was prepared on the basis of the MLI position of the Republic of India submitted to the Depositary upon ratification on 25 June 2019 and of the MLI position of the United Kingdom submitted to the Depositary .....

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..... on as modified by the provisions of the MLI, provided such provisions of the MLI have taken effect. References The copies of the legal texts of the MLI and the Convention can be found at the following links: The MLI: http://www.oecd.org/tax/treaties/multilateral-convention-to-implement-tax-treaty-related-measures-to-prevent-BEPS.pdf In the Republic of India: https://www.incometaxindia.gov.in/Pages/international-taxation/dtaa.aspx In the United Kingdom: http://www.legislation.gov.uk/uksi/1993/1801/contents/made http://www.legislation.gov.uk/uksi/2013/3147/contents/made The MLI position of the Republic of India submitted to the Depositary upon ratification on 25 June 2019 and of the MLI position of the United Kingdom submitted to the Deposita .....

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..... tal gains tax. CONVENTION BETWEEN THE GOVERNMENT OF THE REPUBLIC OF INDIA AND THE GOVERNMENT OF THE UNITED KINGDOM OF GREAT BRITAIN AND NORTHERN IRELAND FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME AND CAPITAL GAINS The Government of the Republic of India and the Government of the United Kingdom of Great Britain and Northern Ireland; Desiring to conclude a new Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and capital gains; The 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 taxati .....

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