India's Central Board of Direct Taxes (CBDT) published Notification No. 33/2024 on 19 March 2024, which concerns the activation of the MFN clause contained in the final protocol to the 1993 income and capital tax treaty with Spain. The MFN clause provides that if under a tax treaty between India and a third State that is a member of the OECD enters into force after 1 January 1990, India limits its taxation at source on royalties or fees for technical services to a rate lower than the rate un…