Multilateral Instruments & General Anti-Avoidance Rules: An Interplay

A. The genesis of Multilateral Instruments A.1. Introduction  Multinationals (“MNCs”) operates in various countries, and such entities may be taxed both the countries, i.e. country of their residence as well as the source country. Countries enter into treaties to avoid double taxation in the source as well as resident countries. Such treaties are generally referred…