Treaty abuse prevention: mandatory preamble to stop treaty-shopping and non-taxation, with Depositary notification mechanisms. Article 6 requires modification of the preamble of each Covered Tax Agreement to state the intent to eliminate double taxation while preventing opportunities for non taxation or reduced taxation through tax evasion or avoidance, including treaty shopping. Parties may optionally add a preamble about developing economic relations and enhanced cooperation in tax matters if all Contracting Jurisdictions notify the Depositary; a Party may reserve non application for agreements with equivalent existing preambular language. Notifications to the Depositary determine whether the specified text replaces or is added to existing preambles.
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.
Treaty abuse prevention: mandatory preamble to stop treaty-shopping and non-taxation, with Depositary notification mechanisms.
Article 6 requires modification of the preamble of each Covered Tax Agreement to state the intent to eliminate double taxation while preventing opportunities for non taxation or reduced taxation through tax evasion or avoidance, including treaty shopping. Parties may optionally add a preamble about developing economic relations and enhanced cooperation in tax matters if all Contracting Jurisdictions notify the Depositary; a Party may reserve non application for agreements with equivalent existing preambular language. Notifications to the Depositary determine whether the specified text replaces or is added to existing preambles.
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