Entry into force determines when the tax treaty applies, making withholding and other tax rules effective from following calendar year. The Agreement enters into force upon exchange of written diplomatic notifications of completed domestic procedures, with effect from the later notification date. Withholding tax provisions apply to income derived in the calendar year following entry into force; other taxes on income and taxes on capital apply to taxable years beginning in the calendar year following entry into force, with India and Luxembourg applying these timing rules according to their respective calendar-year starting points.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Entry into force determines when the tax treaty applies, making withholding and other tax rules effective from following calendar year.
The Agreement enters into force upon exchange of written diplomatic notifications of completed domestic procedures, with effect from the later notification date. Withholding tax provisions apply to income derived in the calendar year following entry into force; other taxes on income and taxes on capital apply to taxable years beginning in the calendar year following entry into force, with India and Luxembourg applying these timing rules according to their respective calendar-year starting points.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.