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The “unique” limitation of benefits article (LOB) - India-Spain DTAA

September 7, 2019[2019] 109 61 (Article)
India has notified double taxation avoidance agreement (‘DTAA’) with Spain on 21st April, 1995. In order to amend the said DTAA, a protocol was signed between India and Spain on 26th October, 2012. The Government of India exercising the power accorded by section 90 of Income Tax Act, 1961 notified the 2012 protocol vide Notification No. 58/2019/F. No. 503/02/1986-FTD-I dated 27th August, 2019, though, the date of entry into force of the said amending Protocol is 29th December, 2014.
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