Taxes on income scope: treaty covers all income taxes and substantially similar future taxes with mutual notification. The Convention applies to taxes on income levied by a Contracting State or its subdivisions regardless of manner of levy, and includes taxes on total income or elements of income such as gains from alienation and taxes on wages or salaries. It lists existing covered taxes-personal income tax, corporate income tax, local surtax, and income tax with surcharge-and extends to identical or substantially similar taxes imposed after signature, with competent authorities required to notify each other of substantial changes in taxation laws.
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.
Taxes on income scope: treaty covers all income taxes and substantially similar future taxes with mutual notification.
The Convention applies to taxes on income levied by a Contracting State or its subdivisions regardless of manner of levy, and includes taxes on total income or elements of income such as gains from alienation and taxes on wages or salaries. It lists existing covered taxes-personal income tax, corporate income tax, local surtax, and income tax with surcharge-and extends to identical or substantially similar taxes imposed after signature, with competent authorities required to notify each other of substantial changes in taxation laws.
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