Termination of tax treaty via diplomatic notice triggers different effective dates for income, withholding and capital tax rules. Termination permits either Contracting State to end the Convention via diplomatic channels after an initial minimum term by giving advance notice before year end; the timing rules differ by State: in India termination affects income from any previous year on or after the first April following the calendar year of notice and capital held at the expiry of previous years beginning on or after that April; in the Czech Republic termination affects withholding taxes for income paid or credited on or after the first January following the calendar year of notice and other income and capital taxes for taxable years beginning on or after that January.
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Provisions expressly mentioned in the judgment/order text.
Termination of tax treaty via diplomatic notice triggers different effective dates for income, withholding and capital tax rules.
Termination permits either Contracting State to end the Convention via diplomatic channels after an initial minimum term by giving advance notice before year end; the timing rules differ by State: in India termination affects income from any previous year on or after the first April following the calendar year of notice and capital held at the expiry of previous years beginning on or after that April; in the Czech Republic termination affects withholding taxes for income paid or credited on or after the first January following the calendar year of notice and other income and capital taxes for taxable years beginning on or after that January.
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