Multilateral treaty modifications restrict treaty benefits for residents and implement anti treaty shopping measures under the tax agreement. The Agreement applies to persons resident of one or both Contracting States; Personal Scope is residency-based and the MLI modifies treaty benefits. Paragraph 1 of Article 11 of the MLI preserves each State's right to tax its residents except as to specified treaty benefits, and MLI provisions take effect according to the Parties' ratification choices and the type of tax involved.
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.
Multilateral treaty modifications restrict treaty benefits for residents and implement anti treaty shopping measures under the tax agreement.
The Agreement applies to persons resident of one or both Contracting States; Personal Scope is residency-based and the MLI modifies treaty benefits. Paragraph 1 of Article 11 of the MLI preserves each State's right to tax its residents except as to specified treaty benefits, and MLI provisions take effect according to the Parties' ratification choices and the type of tax involved.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 
Join Channel
TaxTMI 
