Termination of double taxation agreement: notice triggers deferred cessation aligned to assessment year timing and replacement treaties. Termination is effected by bilateral notice after an initial five year term, with cessation applying only to specified future assessment years in each State, thereby deferring operational effect to align with domestic tax year starts. Additionally, conclusion of a comprehensive double taxation agreement on income, including international air transport income, causes the existing Agreement to cease on the new Agreement's entry into force, irrespective of prior notice.
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Provisions expressly mentioned in the judgment/order text.
Termination of double taxation agreement: notice triggers deferred cessation aligned to assessment year timing and replacement treaties.
Termination is effected by bilateral notice after an initial five year term, with cessation applying only to specified future assessment years in each State, thereby deferring operational effect to align with domestic tax year starts. Additionally, conclusion of a comprehensive double taxation agreement on income, including international air transport income, causes the existing Agreement to cease on the new Agreement's entry into force, irrespective of prior notice.
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