Residence-based scope extends treaty application to persons resident in one or both contracting states, defining taxable nexus. The Agreement establishes a residence-based scope: it applies to persons who are residents of one or both Contracting States, defining which taxpayers may invoke treaty provisions. The treaty entered into force after mutual notification and has been given effect domestically by the Central Government to apply its provisions in relation to taxes on income and prevention of fiscal evasion.
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.
Residence-based scope extends treaty application to persons resident in one or both contracting states, defining taxable nexus.
The Agreement establishes a residence-based scope: it applies to persons who are residents of one or both Contracting States, defining which taxpayers may invoke treaty provisions. The treaty entered into force after mutual notification and has been given effect domestically by the Central Government to apply its provisions in relation to taxes on income and prevention of fiscal evasion.
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