Summary of changes to Preamble | Article 6 | MLI

 

Article 6 of MLI introduces changes in the Preamble of the Covered Tax Agreements. It is a minimum standard as recommended under BEPS Action 6 report. We have discussed in detail the preamble stated under Article 6 of MLI in our previous post. Click here to read it. MLI preamble will be in place of … Continue reading Summary of changes to Preamble | Article 6 | MLI

Article 6 of MLI – Purpose of Covered Tax Agreement

 

Article 6 of MLI provides the preamble and purpose of the Covered Tax Agreement. BEPS Action 6 acknowledges that preamble is an essential source for interpreting treaties as the same provides clear intent or a rationale that persuaded two countries to enter into a treaty. According to the basic rule of interpretation of treaties in … Continue reading Article 6 of MLI – Purpose of Covered Tax Agreement