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 satisfied:
- India’s DTAA with the country which has a lower rate or restricted scope (the third State) is ent…