India's Central Board of Direct taxes has issued Circular No. 3/2022 of 3 February 2022, providing clarification regarding the Most-Favored-Nation (MFN) clause in India's tax treaties. In particular, the circular addresses the tax treaties with France, the Netherlands, and Switzerland, the competent authorities of which have issued decisions that the MFN clause of the relevant treaty with India was triggered by treaties with countries that were not OECD members when the treaties with India were signed, but subsequently became OECD members. These include India's tax treaties with Slovenia, Colombia, and Lithuania, which provide for a lower rate of withholding tax...