Covered Tax Agreement scope clarified: notification to the depositary determines inclusion and treaty terms govern undefined terms. A Covered Tax Agreement is an in-force agreement to avoid double taxation on income that a Party has listed to the Depositary (including amending or accompanying instruments) as one it wishes to be covered by the Convention; only such notified agreements fall within scope. Terms not defined in the Convention take, for application by a Party, the meaning they have at that time under the relevant Covered Tax Agreement.
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.
Covered Tax Agreement scope clarified: notification to the depositary determines inclusion and treaty terms govern undefined terms.
A Covered Tax Agreement is an in-force agreement to avoid double taxation on income that a Party has listed to the Depositary (including amending or accompanying instruments) as one it wishes to be covered by the Convention; only such notified agreements fall within scope. Terms not defined in the Convention take, for application by a Party, the meaning they have at that time under the relevant Covered Tax Agreement.
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