Multilateral Convention to Implement Tax Treaty related Measures to Prevent Base Erosion & Profit Shifting

Multilateral Convention to Implement Tax Treaty related Measures to Prevent Base Erosion and Profit Shifting signed by India on 7th day of June, 2017;

MINISTRY OF FINANCE
(Department of Revenue)
(INCOME TAX)

Notification No. 57/2019

New Delhi, the 9th August, 2019

S.O. 2887(E).—Whereas the Multilateral Convention to Implement Tax Treaty related Measures to Prevent Base Erosion and Profit Shifting (hereinafter referred to as the “the said Convention”) was signed by India at Paris, France on the 7th day of June, 2017;

And whereas, the said Convention entered into force on the 01st day of July, 2018, being the first day of month following expiration of three calendar months beginning on the date of deposit of the fifth instrument of ratification, in accordance with para 1 of Article 34 of the said Convention;

And whereas, India had ratified the said Convention and had deposited the instrument of ratification along-with the list of Covered Tax Agreements, reservations and notifications (hereinafter referred to as “India’s Position under the said Convention”) to the Depositary as in Article 39 of the said Convention, on the 25th day of June, 2019;

And whereas, the date of entry into force of the said Convention for India is the 01st day of October, 2019, being the first day of the month following the expiration of a period of three calendar months beginning on the 25th day of June, 2019 being the date of deposit by India of the instrument of ratification, in accordance with para 2 of Article 34 of the said Convention;

And whereas, the provisions of the said Convention shall have effect in India with respect to a Covered Tax Agreement in accordance with provisions of Article 35 of the said Convention;

Now, therefore, in exercise of the powers conferred by sub-section (1) of section 90 of the Income-tax Act, 1961 (43 of 1961), the Central Government hereby notifies that the provisions of the said Convention shall be given effect to in the Union of India, in accordance with India’s Position under the said Convention, as set out in the Annexure hereto.

Annexure

Multilateral Convention To Implement Tax Treaty Related Measures To Prevent Base Erosion And Profit Shifting

F. No. 500/71/2015-FTD-I

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