Entry into force of tax treaty: diplomatic notification triggers staggered application to withholding and period-based taxes. The Convention enters into force upon reciprocal written notification through diplomatic channels and takes effect on the date of that notification letter. Withholding taxes on dividends, interest, royalties and fees for technical services apply to amounts paid or credited on or after the first day of the month following entry into force, whereas taxes on income and taxes on capital apply for fiscal or taxable periods beginning on or after each Contracting State's specified commencement date.
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Provisions expressly mentioned in the judgment/order text.
Entry into force of tax treaty: diplomatic notification triggers staggered application to withholding and period-based taxes.
The Convention enters into force upon reciprocal written notification through diplomatic channels and takes effect on the date of that notification letter. Withholding taxes on dividends, interest, royalties and fees for technical services apply to amounts paid or credited on or after the first day of the month following entry into force, whereas taxes on income and taxes on capital apply for fiscal or taxable periods beginning on or after each Contracting State's specified commencement date.
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