Double taxation agreement applies to residents and is implemented domestically after entry into force for income taxation.

The Central Government has notified the Double Taxation Agreement with Hong Kong under section 90, declaring the Agreement effective domestically upon its entry into force and stating that its provisions apply in India to income arising in fiscal years beginning on or after the first fiscal year following entry into force. Article 1 provides that the Agreement applies to persons who are residents of one or both Contracting Parties, establishing the residence-based scope for the Agreement's income tax provisions.

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