Personal scope and MLI modifications clarify how treaty provisions apply to residents under the amended tax convention. The Convention applies to persons resident in one or both Contracting States under the personal scope provision and is presented as modified by the MLI, with MLI provisions incorporated where they have taken effect and subject to each Party's MLI positions and entry-into-effect conditions; the authentic Convention and MLI texts remain authoritative, and terminology changes in the synthesis are for readability without altering substance.
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.
Personal scope and MLI modifications clarify how treaty provisions apply to residents under the amended tax convention.
The Convention applies to persons resident in one or both Contracting States under the personal scope provision and is presented as modified by the MLI, with MLI provisions incorporated where they have taken effect and subject to each Party's MLI positions and entry-into-effect conditions; the authentic Convention and MLI texts remain authoritative, and terminology changes in the synthesis are for readability without altering substance.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 
TaxTMI 
