Taxes on income and capital extend to existing and similar taxes with a mutual notification obligation. Article 2 provides that the Convention applies to taxes on income and on capital imposed on behalf of a Contracting State or its subdivisions, regardless of how they are levied. It defines such taxes to include taxes on total income or capital, elements of income or capital, gains from alienation, wages paid by enterprises, and capital appreciation, and extends application to identical or substantially similar taxes enacted later, with competent authorities required to notify each other of significant tax-law changes.
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 and capital extend to existing and similar taxes with a mutual notification obligation.
Article 2 provides that the Convention applies to taxes on income and on capital imposed on behalf of a Contracting State or its subdivisions, regardless of how they are levied. It defines such taxes to include taxes on total income or capital, elements of income or capital, gains from alienation, wages paid by enterprises, and capital appreciation, and extends application to identical or substantially similar taxes enacted later, with competent authorities required to notify each other of significant tax-law changes.
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