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India High Court Holds Application of Reduced Treaty Rate Due to MFN Clause May be Claimed in Revision Petition

|Treaty Development|India-Spain
India-Spain

The Delhi High Court has published a 10 July 2019 decision concerning whether a taxpayer may claim a reduced withholding tax rate due to the MFN clause of a tax treaty through a revision petition.

The case involved a company incorporated in Spain, Epcos Electronic Components SA (now TDK), which had applied a 20% withholding tax rate for management services provided to its associated enterpris…

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