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..... ublic of India and the Government of the Portuguese Republic for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income signed on 11th September, 1998 and the Amending Protocol signed on 24th June, 2017 (together hereinafter referred to as the Convention ), as modified by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting signed by India and Portugal on 7th June, 2017 (hereinafter referred to as the MLI ). This document was prepared on the basis of the reservations and notifications submitted to the Depositary (the Secretary-General of the Organisation for Economic Co-operation and Development), upon ratification, by India on 25th Ju .....

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..... d to change the substance of the provisions of the MLI. Unless the context otherwise requires, references made to the provisions of the Convention will be understood as referring to the provisions of the Convention as modified by the provisions of the MLI. References: In India: The authentic legal text of the MLI (in English) can be found on the MLI Depositary (OECD) webpage at the following 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 Convention (in English) can be found at the following link: https://www.incometaxindia.gov.in/Pages/international-taxation/dtaa.aspx In Portugal: The authentic legal text of the MLI can be found at t .....

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..... ng on or after 1st April, 2021. In Portugal: 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 1st January, 2021; and with respect to all other taxes levied by Portugal, for taxes levied with respect to taxable periods beginning on or after 1st December, 2020. CONVENTION BETWEEN THE GOVERNMENT OF THE REPUBLIC OF INDIA AND THE GOVERNMENT OFTHE PORTUGUESE REPUBLIC FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME The Government of the Republic of India and the Government of the Portuguese Republic, desiring to conclude a Convention for the avoidance of double taxation and the prevention of f .....

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