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..... rbia) for the Avoidance of Double Taxation with respect to Taxes on Income and on Capital signed on 8th February 2006 (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 (India) and the Republic of Serbia (Serbia) on 7th June 2017 (the MLI ). This document was prepared jointly by the competent authorities of India and Serbia 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 India submitted to the Depositary upon ratification on 25th June 2019 and MLI position of Serbia submitted to the Depositary upon ratifi .....

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..... fied by the provisions of the MLI, provided such provisions of the MLI have taken effect. References The authentic legal text of the MLI can be found on the MLI Depositary (OECD) webpage: in English: https://www.oecd.org/tax/treaties/multilateral-convention-to-implement-tax-treaty-related- easures-to-prevent-BEPS.pdf ; and in French: http://www.oecd.org/fr/fiscalite/conventions/convention-multilaterale-pour-la-mise-en-oeuvre-des-mesures-relatives-aux-conventions-fiscales-pour-prevenir-le-BEPS.pdf. The authentic legal text of the Convention (in English) can be found at the following link: https://www.incometaxindia.gov.in/Pages/international-taxation/dtaa.aspx The MLI position of India submitted to the Depositary upon ratification on 25th Ju .....

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..... . CONVENTION BETWEEN THE GOVERNMENT OF THE REPUBLIC OF INDIA AND THE COUNCIL OF MINISTERS OF SERBIA AND MONTENEGRO FOR THE AVOIDANCE OF DOUBLE TAXATION WITH RESPECT TO TAXES ON INCOME AND ON CAPITAL THE GOVERNMENT OF THE REPUBLIC OF INDIA AND THE COUNCIL OF MINISTERS OF SERBIA AND MONTENEGRO desiring to conclude a Convention for the avoidance of double taxation with respect to taxes on income and on capital 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 Convention: ARTICLE 6 OF THE MLI - PURPOSE OF A COVERED TAX AGREEMENT Intending to eliminate double taxation with respect to the taxes covered by [1] this Convention without c .....

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