Personal scope of tax treaty: applies to residents of one or both Contracting States and gives treaty effect. The India-Belarus Agreement was notified as entering into force and the Central Government directed that the Agreement's provisions be given effect domestically for taxes on income and property. Article 1 sets the personal scope: the Agreement applies to persons who are residents of one or both Contracting States, making residence the governing criterion for treaty coverage.
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Provisions expressly mentioned in the judgment/order text.
Personal scope of tax treaty: applies to residents of one or both Contracting States and gives treaty effect.
The India-Belarus Agreement was notified as entering into force and the Central Government directed that the Agreement's provisions be given effect domestically for taxes on income and property. Article 1 sets the personal scope: the Agreement applies to persons who are residents of one or both Contracting States, making residence the governing criterion for treaty coverage.
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