Double taxation avoidance applies to residents of contracting states under the treaty, covering taxes on income and capital. The Agreement provides for avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income and capital and applies to persons who are residents of one or both Contracting States; it operates by allocating taxing rights and providing relief mechanisms, and has been given domestic effect through implementing notification.
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Provisions expressly mentioned in the judgment/order text.
Double taxation avoidance applies to residents of contracting states under the treaty, covering taxes on income and capital.
The Agreement provides for avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income and capital and applies to persons who are residents of one or both Contracting States; it operates by allocating taxing rights and providing relief mechanisms, and has been given domestic effect through implementing notification.
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