Presentations

Interpretation of MLI - [Nov 2024] NEW
Abstract : The Multilateral Instrument signed in 2016 to give effect to the BEPS measures in treaties, gives rise to interesting issues for interpretation. The Presentation describes the conflict between the Covered Tax agreement and the MLI and the application of the compatibility clauses in the MLI which act as conflict rules. The various tools for interpretation of the MLI based on the articles of the Vienna Convention are enumerated. The impact of notifications mismatch on the CTA is explored. How and to what extent treaties entered into by India are impacted is discussed though interesting examples. Mismatch of notifications and inappropriate reservations made as well as the usefulness (or lack of it) of the Synthesised Texts are discussed. 

MLI Article 13 on Specific Activities Exemption - A case study [August 2020]