Entry into Effect timing: Convention applies to withholding and other taxes after specified calendar and post-notification periods. The Convention sets separate commencement rules: withholding taxes apply where the taxable event occurs on or after the first day of the next calendar ... Summary
Entry into Effect timing: Convention applies to withholding and other taxes after specified calendar and post-notification periods.
The Convention sets separate commencement rules: withholding taxes apply where the taxable event occurs on or after the first day of the next calendar year following entry into force for the Contracting Jurisdictions to a Covered Tax Agreement; other taxes apply for taxable periods beginning after a prescribed post-entry lapse, subject to unanimous shortening. Parties may opt to substitute "taxable period" for "calendar year" or to replace entry-date references with notification-based references tied to Depositary receipt of confirmations of domestic completion. Article 16 (Mutual Agreement Procedure) also has specified commencement rules, subject to reservation.
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