Termination of tax treaty: notice triggers cessation of treaty benefits for subsequent fiscal and assessment periods under specified notice rules. Termination is effected by diplomatic notice given at least six months before the end of any calendar year beginning after five years from entry into force. In India the Convention ceases to apply to income arising in any fiscal year beginning on or after the first day of April following the calendar year in which notice is given. In Ireland the Convention ceases to apply for income-tax and capital gains tax for any year of assessment beginning on or after the sixth day of April in the year following the calendar year of notice, and for corporation tax for any financial year beginning on or after the first day of January in the year following the calendar year of notice.
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.
Termination of tax treaty: notice triggers cessation of treaty benefits for subsequent fiscal and assessment periods under specified notice rules.
Termination is effected by diplomatic notice given at least six months before the end of any calendar year beginning after five years from entry into force. In India the Convention ceases to apply to income arising in any fiscal year beginning on or after the first day of April following the calendar year in which notice is given. In Ireland the Convention ceases to apply for income-tax and capital gains tax for any year of assessment beginning on or after the sixth day of April in the year following the calendar year of notice, and for corporation tax for any financial year beginning on or after the first day of January in the year following the calendar year of notice.
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