Residual taxation rule: domestic law governs assessment and taxation except where the treaty provides otherwise. Residual taxation under the DTAA preserves each Contracting State's domestic law for assessment and taxation except where the treaty expressly provides otherwise; domestic statutes, rules, and procedures determine tax liability and administration unless an explicit treaty provision displaces those domestic rules.
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.
Residual taxation rule: domestic law governs assessment and taxation except where the treaty provides otherwise.
Residual taxation under the DTAA preserves each Contracting State's domestic law for assessment and taxation except where the treaty expressly provides otherwise; domestic statutes, rules, and procedures determine tax liability and administration unless an explicit treaty provision displaces those domestic rules.
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