Citation: G. Manzi, N.Jalan, Recent Developments on the Application of the Most Favoured Nation Clauses in Tax Treaties – The Indian Case Study, 9º Congresso Brasileiro de Direito Tributário Internacional IBDT/DEF-USP IBDT
The Indian Central Board of Direct Taxes issued a Circular in February 2022 stating its position on the activation of the Most Favoured Nation clauses included in the tax treaties concluded by India with the Netherlands, France, and Switzerland. The paper aims to analyze such documents and, therefore, the point of view of the Indian Government on this topic. It starts with an overview of the facts and circumstances taken into consideration in the Circular and then assesses critically the different approaches and principles stated by the Central Board of Direct Taxes in the same document.
The views in all sections are personal views of the author.