Termination of tax treaty: diplomatic notice triggers phased cessation across categories of taxes and specified effective dates. Termination permits either Contracting State to give written diplomatic notice after the initial period, triggering phased cessation: one State's income and capital taxation ends for fiscal periods beginning on or after the fiscal date following the year of notice; the other State's taxes on dividends, interest and royalties cease for payments after a short notice period, enterprise taxes cease for taxable periods starting on the first day of the calendar year following the year of notice, and individual income taxes cease for payments after the short notice period.
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.
Termination of tax treaty: diplomatic notice triggers phased cessation across categories of taxes and specified effective dates.
Termination permits either Contracting State to give written diplomatic notice after the initial period, triggering phased cessation: one State's income and capital taxation ends for fiscal periods beginning on or after the fiscal date following the year of notice; the other State's taxes on dividends, interest and royalties cease for payments after a short notice period, enterprise taxes cease for taxable periods starting on the first day of the calendar year following the year of notice, and individual income taxes cease for payments after the short notice period.
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