Entry into force: treaty applies after reciprocal notification, with staggered fiscal-year implementation in each Contracting State. The Agreement enters into force on the later date of reciprocal written notifications through diplomatic channels confirming completion of internal procedures. Its provisions apply under staggered fiscal rules: for taxes withheld at source and for other taxes on income and capital, each Contracting State applies the treaty from the first January or April of the calendar year following the year in which the Agreement enters into force, respectively.
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Provisions expressly mentioned in the judgment/order text.
Entry into force: treaty applies after reciprocal notification, with staggered fiscal-year implementation in each Contracting State.
The Agreement enters into force on the later date of reciprocal written notifications through diplomatic channels confirming completion of internal procedures. Its provisions apply under staggered fiscal rules: for taxes withheld at source and for other taxes on income and capital, each Contracting State applies the treaty from the first January or April of the calendar year following the year in which the Agreement enters into force, respectively.
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