Entry into force clarifies DTAA's commencement and retrospective application to income for specified fiscal years. Article 28 requires each Contracting State to notify the other when domestic procedures for bringing the DTAA into force are complete; the Agreement enters into force on the later notification date and, upon entry into force, applies retrospectively to income for specified fiscal years in the respective States.
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Provisions expressly mentioned in the judgment/order text.
Entry into force clarifies DTAA's commencement and retrospective application to income for specified fiscal years.
Article 28 requires each Contracting State to notify the other when domestic procedures for bringing the DTAA into force are complete; the Agreement enters into force on the later notification date and, upon entry into force, applies retrospectively to income for specified fiscal years in the respective States.
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