Entry into force of tax treaty triggers staggered application to income, capital gains, and corporation tax provisions. Article 28 requires mutual written notification through diplomatic channels of completion of domestic entry into force procedures; the Convention enters into force thirty days after receipt of the later notification. Its application is staggered: in India it applies to income for fiscal years beginning on or after the first of April following the calendar year in which the Convention enters into force; in Ireland it applies to income tax and capital gains tax for years of assessment beginning on or after the sixth of April in the year following entry into force, and to corporation tax for financial years beginning on or after the first of January in the year following entry into force.
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.
Entry into force of tax treaty triggers staggered application to income, capital gains, and corporation tax provisions.
Article 28 requires mutual written notification through diplomatic channels of completion of domestic entry into force procedures; the Convention enters into force thirty days after receipt of the later notification. Its application is staggered: in India it applies to income for fiscal years beginning on or after the first of April following the calendar year in which the Convention enters into force; in Ireland it applies to income tax and capital gains tax for years of assessment beginning on or after the sixth of April in the year following entry into force, and to corporation tax for financial years beginning on or after the first of January in the year following entry into force.
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