Entry into force of tax treaty: mutual notification triggers effect and fiscal-year commencement determines applicability. The Convention enters into force upon mutual written notification through diplomatic channels, with effect from the later such notification; its provisions apply to each Contracting State in respect of taxes on income and taxes on capital for fiscal years beginning on or after the first fiscal-year start following the year in which the Convention enters into force.
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Provisions expressly mentioned in the judgment/order text.
Entry into force of tax treaty: mutual notification triggers effect and fiscal-year commencement determines applicability.
The Convention enters into force upon mutual written notification through diplomatic channels, with effect from the later such notification; its provisions apply to each Contracting State in respect of taxes on income and taxes on capital for fiscal years beginning on or after the first fiscal-year start following the year in which the Convention enters into force.
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