Executive summary

On 3 February 2022, the Indian Government issued a Circular¹ clarifying the applicability of the Most Favored Nation (MFN) clause found in some of India’s Double Taxation Avoidance Agreements (DTAAs). The Circular restricts the applicability of the MFN clause in a DTAA between India and another country (the second State) to cases where all the following conditions are satisfi…