Entry into force of tax treaty delays application to source withholding and other taxes until subsequent fiscal years. The Agreement enters into force upon mutual notification that constitutional requirements have been met, and applies prospectively: in Canada to source-withheld amounts and other taxes for taxable periods beginning on the first day of January in the calendar year following entry into force; in India to income and to capital held at the end of fiscal years beginning on the first day of April in the calendar year following entry into force. The 1985 Agreement ceases to have effect for taxes covered by the new Agreement and terminates on the last day it remains effective under these provisions.
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Provisions expressly mentioned in the judgment/order text.
Entry into force of tax treaty delays application to source withholding and other taxes until subsequent fiscal years.
The Agreement enters into force upon mutual notification that constitutional requirements have been met, and applies prospectively: in Canada to source-withheld amounts and other taxes for taxable periods beginning on the first day of January in the calendar year following entry into force; in India to income and to capital held at the end of fiscal years beginning on the first day of April in the calendar year following entry into force. The 1985 Agreement ceases to have effect for taxes covered by the new Agreement and terminates on the last day it remains effective under these provisions.
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