Termination of tax treaty requires diplomatic notice and triggers cessation with differing effective dates for withholding and other taxes. Article 33 allows either Contracting State to terminate the double taxation agreement via diplomatic notice given at least six months before year-end after five years in force. The Article distinguishes withholding taxes from other taxes on income and taxes on capital, and prescribes that cessation of treaty benefits takes effect from the start of the calendar year (or the taxable year beginning on the first day of that calendar year) next following the year in which notice is given, with each Contracting State applying those effective-date rules according to its fiscal year conventions.
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 requires diplomatic notice and triggers cessation with differing effective dates for withholding and other taxes.
Article 33 allows either Contracting State to terminate the double taxation agreement via diplomatic notice given at least six months before year-end after five years in force. The Article distinguishes withholding taxes from other taxes on income and taxes on capital, and prescribes that cessation of treaty benefits takes effect from the start of the calendar year (or the taxable year beginning on the first day of that calendar year) next following the year in which notice is given, with each Contracting State applying those effective-date rules according to its fiscal year conventions.
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