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Concentrix Services Netherlands: Applying Common Interpretation Principle to Dividend MFN Clause

ADMIN

Recently Delhi High Court in the case of Concentrix Services Netherlands BV v ITO ( 1 had the opportunity to interpret the Most Favoured Nation MFN clause in the protocol to India Netherlands tax treaty The High Court held that the lower withholding tax rate of 5 %%(on dividend) provided in Indian tax treaties viz Slovenia, Colombia and Lithuania would equally apply to the Indo Dutch Remittance in view of the MFN clause under the India Netherlands tax treaty.



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