Entry into force timing for a tax treaty delays application until the calendar year following mutual notification. Each Contracting State must notify the other through diplomatic channels when domestic procedures for the Agreement are complete; the Agreement enters into force on the later notification. The Agreement applies, for withholding taxes, to income paid or credited on or after the first day of the calendar year following entry into force, and, for other taxes on income and on capital, to taxes chargeable for any fiscal year beginning on or after that first day, with the timing specified separately for each State.
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Provisions expressly mentioned in the judgment/order text.
Entry into force timing for a tax treaty delays application until the calendar year following mutual notification.
Each Contracting State must notify the other through diplomatic channels when domestic procedures for the Agreement are complete; the Agreement enters into force on the later notification. The Agreement applies, for withholding taxes, to income paid or credited on or after the first day of the calendar year following entry into force, and, for other taxes on income and on capital, to taxes chargeable for any fiscal year beginning on or after that first day, with the timing specified separately for each State.
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