Covered Tax Agreement purpose: anti-abuse measures added to the treaty change relief and timing of application. The Multilateral Instrument modifies the bilateral Agreement by adding anti abuse purpose provisions and aligning terminology, while preserving the Agreement and MLI as the authoritative texts. The Agreement applies to persons who are residents of one or both Contracting States. MLI provisions take effect for the Agreement according to each Party's notified positions and vary by tax type, distinguishing between withholding taxes and other taxes pursuant to the Parties' ratification, approval and entry into force notifications.
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.
Covered Tax Agreement purpose: anti-abuse measures added to the treaty change relief and timing of application.
The Multilateral Instrument modifies the bilateral Agreement by adding anti abuse purpose provisions and aligning terminology, while preserving the Agreement and MLI as the authoritative texts. The Agreement applies to persons who are residents of one or both Contracting States. MLI provisions take effect for the Agreement according to each Party's notified positions and vary by tax type, distinguishing between withholding taxes and other taxes pursuant to the Parties' ratification, approval and entry into force notifications.
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