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In June this year, India signed the Multilateral Convention (MLC) to implement tax treaty-related measures to prevent base erosion and profit shifting under the BEPS project. MLC seeks to modify a large number of tax treaties. The modification principally works on a reciprocal basis where countries notify (a) the treaties to which they intend to apply the MLC and (b) the provisions of the MLC, which they intend to apply to individual treaties.

Rahul Jain, Partner- International Taxation, Nangia Advisors LLP contributed an article on Principal purpose test under BEPS more stringent than GAAR for Business Today magazine.

BEPS GAAR - Rahul Jain