Interplay between MFN clause in India-Netherlands treaty and MLI implementation in India-Slovenia treaty
February 8 2023
Open Access Video
This video deals with the interplay between (a) the most favored nation (MFN) clause in the India-Netherlands tax treaty (in respect of the dividends article) and (b) implementation of Art. 8(1) of the the Multilateral Instrument (MLI) in the India-Slovenia tax treaty. It considers three alternative propositions in respect of the dividends withholding tax implications under the India-Netherlands tax treaty in situations where the 365-day ownership requirement of Art. 8 of the MLI is not satisfied.
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