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..... ernment of Ukraine for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on capital signed on 7th April, 1999 (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 on 7th June, 2017 and Ukraine on 23rd July, 2018 (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 Ukraine submitted to the Depositary upon ratification on 8th August, 2019. These MLI positions are subject to modifications as provided in the MLI. Modifications made to MLI positions coul .....

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..... (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 In India: 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 In Ukraine: the authentic legal text of the Convention (in Ukrainian) can be found at the following link: https://zakon.rada.gov.ua/laws/show/356_010#Text The MLI position of the India submitted to the Depositary upon ratification on 25th June, 2019 and of the MLI position of the Ukraine submitted to the Depositary upon ratification on 8 th August, 2019 can be found .....

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..... MENT OF UKRAINE FOR THE AVOIDANCE OF DOUBLE 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 Ukraine desiring to conclude a Convention for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income and on capital and confirming their aspiration for the development and strengthening of bilateral relations; 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 this [1] Convention without creating opportunities for non-taxation .....

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