Personal scope: Tax treaty applies to persons resident in one or both Contracting States, as modified by the MLI. The Convention applies to persons who are residents of one or both Contracting States; the synthesised text integrates MLI provisions that modify the Convention where those MLI provisions have taken effect, while preserving the authentic legal texts of the Convention and the MLI as the controlling instruments.
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: Tax treaty applies to persons resident in one or both Contracting States, as modified by the MLI.
The Convention applies to persons who are residents of one or both Contracting States; the synthesised text integrates MLI provisions that modify the Convention where those MLI provisions have taken effect, while preserving the authentic legal texts of the Convention and the MLI as the controlling instruments.
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