Tax treaty scope clarified: exclusions for penalties, business tax exemption, and defined government financial institution carve outs. The Protocol clarifies that the term tax under Article 3(1)(d) excludes penalties for non compliance; extends Article 8 exemptions to include the business tax in one State and any similar tax subsequently imposed in the other; and defines the Central Bank and specified government owned financial institutions qualifying for treaty treatment under Article 11(3), while preserving competent authorities' ability to agree on additional institutions and information exchange arrangements.
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.
Tax treaty scope clarified: exclusions for penalties, business tax exemption, and defined government financial institution carve outs.
The Protocol clarifies that the term tax under Article 3(1)(d) excludes penalties for non compliance; extends Article 8 exemptions to include the business tax in one State and any similar tax subsequently imposed in the other; and defines the Central Bank and specified government owned financial institutions qualifying for treaty treatment under Article 11(3), while preserving competent authorities' ability to agree on additional institutions and information exchange arrangements.
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