Dual resident entities rule confirms treaty tie breaker application, listing covered agreements and specified jurisdictional deviations. India notifies, under the BEPS Convention, that specified bilateral tax agreements contain a dual resident entities tie breaker provision corresponding to Article 4(2) and not subject to Article 4(3)(b)-(d) reservations. The notification lists each contracting jurisdiction and the particular Article 4 paragraph relied on; most are Article 4(3), while Japan is recorded as Article 4(2), Kuwait and United Arab Emirates as Article 4(4), and the United States as Article 4(3) and (4).
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.
Dual resident entities rule confirms treaty tie breaker application, listing covered agreements and specified jurisdictional deviations.
India notifies, under the BEPS Convention, that specified bilateral tax agreements contain a dual resident entities tie breaker provision corresponding to Article 4(2) and not subject to Article 4(3)(b)-(d) reservations. The notification lists each contracting jurisdiction and the particular Article 4 paragraph relied on; most are Article 4(3), while Japan is recorded as Article 4(2), Kuwait and United Arab Emirates as Article 4(4), and the United States as Article 4(3) and (4).
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