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Opinion: Interplay between India-Netherlands tax treaty's Art. 10(2) read with MFN clause and implementation of MLI Art. 8(1) in the India-Slovenia tax treaty

 By: Dr. Amar Mehta  -  November 22, 2020

 In view of the most favored nation (MFN) clause in the India-Netherlands tax treaty, can a Netherlands company directly and beneficially owning at least 10% capital of an Indian company apply the lower dividend withholding tax stipulated in the India-Slovenia tax treaty even if it does not satisfy the 365-day ownership requirement of Art. 8(1) of the MLI?

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