Termination of tax treaty ends treaty benefits, affecting withholding tax and other income taxes for subsequent tax periods. Termination of the India-Russia tax treaty requires diplomatic notice after five years, given at least six months before year end. The treaty's cessation is phased: in Russia it stops applying to source withheld taxes for income arising from the calendar year following the notice year and to other income taxes for fiscal years beginning then; in India it ceases to apply to income arising in any fiscal year beginning on or after the fiscal year that follows the calendar year in which notice is given.
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Provisions expressly mentioned in the judgment/order text.
Termination of tax treaty ends treaty benefits, affecting withholding tax and other income taxes for subsequent tax periods.
Termination of the India-Russia tax treaty requires diplomatic notice after five years, given at least six months before year end. The treaty's cessation is phased: in Russia it stops applying to source withheld taxes for income arising from the calendar year following the notice year and to other income taxes for fiscal years beginning then; in India it ceases to apply to income arising in any fiscal year beginning on or after the fiscal year that follows the calendar year in which notice is given.
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