Entry into Effect timing: Convention applies to withholding and other taxes after specified calendar and post-notification periods. The Convention sets separate commencement rules: withholding taxes apply where the taxable event occurs on or after the first day of the next calendar year following entry into force for the Contracting Jurisdictions to a Covered Tax Agreement; other taxes apply for taxable periods beginning after a prescribed post-entry lapse, subject to unanimous shortening. Parties may opt to substitute 'taxable period' for 'calendar year' or to replace entry-date references with notification-based references tied to Depositary receipt of confirmations of domestic completion. Article 16 (Mutual Agreement Procedure) also has specified commencement rules, subject to reservation.
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 Effect timing: Convention applies to withholding and other taxes after specified calendar and post-notification periods.
The Convention sets separate commencement rules: withholding taxes apply where the taxable event occurs on or after the first day of the next calendar year following entry into force for the Contracting Jurisdictions to a Covered Tax Agreement; other taxes apply for taxable periods beginning after a prescribed post-entry lapse, subject to unanimous shortening. Parties may opt to substitute "taxable period" for "calendar year" or to replace entry-date references with notification-based references tied to Depositary receipt of confirmations of domestic completion. Article 16 (Mutual Agreement Procedure) also has specified commencement rules, subject to reservation.
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