Notification obligations for tax treaties clarified; timing, territorial scope and reservation effects govern treaty application. Article 29 prescribes the notification regime for the Convention: Parties must notify specified treaty provisions at signature or upon deposit of instruments, may confirm or provisionally list notifications, and may extend notified agreements or make additional notifications to the Depositary. The Article permits different notifications for dependent territories, requires Parties to state applicability of reservations for added agreements, and sets timing rules for when additional notifications take effect in relation to withholding taxes, other taxes, and the Convention's entry into force for Contracting Jurisdictions.
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Provisions expressly mentioned in the judgment/order text.
Notification obligations for tax treaties clarified; timing, territorial scope and reservation effects govern treaty application.
Article 29 prescribes the notification regime for the Convention: Parties must notify specified treaty provisions at signature or upon deposit of instruments, may confirm or provisionally list notifications, and may extend notified agreements or make additional notifications to the Depositary. The Article permits different notifications for dependent territories, requires Parties to state applicability of reservations for added agreements, and sets timing rules for when additional notifications take effect in relation to withholding taxes, other taxes, and the Convention's entry into force for Contracting Jurisdictions.
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