Application of Tax Convention modified by MLI governs treaty scope for residents and sets temporal entry into effect rules. The Convention as modified by the Multilateral Instrument applies to persons who are residents of one or both Contracting States; the synthesised text aligns MLI terminology to the Convention without creating law, records that authentic texts of the Convention and the MLI are the sole legal sources, and specifies that MLI modifications apply subject to each State's reservations and temporal entry into effect rules distinguishing withholding taxes from other taxes.
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.
Application of Tax Convention modified by MLI governs treaty scope for residents and sets temporal entry into effect rules.
The Convention as modified by the Multilateral Instrument applies to persons who are residents of one or both Contracting States; the synthesised text aligns MLI terminology to the Convention without creating law, records that authentic texts of the Convention and the MLI are the sole legal sources, and specifies that MLI modifications apply subject to each State's reservations and temporal entry into effect rules distinguishing withholding taxes from other taxes.
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