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Government of India issues notification to give effect to MFN clause for lower tax rate under India-Spain DTAA
The Government of India (GoI) has issued Notification No. 33/2024 dated 19 March 2024 (Notification)[1], by exercising its powers under the Indian Tax Laws (ITL), conferring lower tax rate benefit of 10% under the India-Spain Double Taxation Avoidance Agreement (DTAA) in accordance with the most favored nation (MFN) clause of the India-Spain DTAA. The benefit has been accorded with reference to royalty and fees for technical services (FTS) payments based on the beneficial treatment provided under the India-Germany DTAA. The amendment is effective from tax year 2023-24.
[1] F.No. 503/2/1986-FTD-I