Synthesized text of India-Japan income tax treaty as affected by Convention to Implement Measures to Prevent to Prevent Base Erosion & Profit Shifting (MLI)
Japan’s Ministry of Finance has released publication of Synthesized Text of Convention to Implement Measures to Prevent to Prevent Base Erosion and Profit Shifting (MLI)
The document presents the synthesised text for the application of the Convention between the Government of Japan and the Government of the Republic of India for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income signed on March 7, 1989, as amended by the Protocol signed on February 24, 2006 and the Protocol signed on December 11, 2015 as modified by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting signed by Japan and India on June 7, 2017.
The Convention to Implement Measures to Prevent BEPS (MLI) is intended to introduce the tax treaty related measures, which are part of the measures developed under the BEPS project, into the existing tax treaties between the Parties to the MLI.
The MLI enables the Parties to implement the tax treaty related measures to prevent BEPS with respect to a large number of their existing tax treaties at the same time and in an efficient manner.
Measures to prevent BEPS introduced into the existing tax treaties by the MLI consist of (i) measures to prevent tax avoidance conducted through abuse of tax treaties and (ii) measures to eliminate uncertainty for taxpayers such as elimination of double taxation.
Each of the Parties to the MLI may choose all or part of its existing tax treaties as to be covered by the MLI and under specified conditions all or part of provisions of the MLI regarding the tax treaty related measures to prevent BEPS as to be applicable to their existing tax treaties.
“Synthesized Text” is a document containing the consolidated text of the provisions of a tax treaty (as it may be amended by amending protocols) and the provisions of the MLI applicable to that tax treaty.
The said document is meant solely for the purpose of facilitating the understanding of the application of the MLI to a tax treaty and has no legal value.
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