Change in company tax rate may trigger treaty consultations and suspension of dividend, interest, royalty and other income provisions. If a Contracting State reduces its general statutory rate of company tax below the threshold or exempts substantially all foreign source income, the States shall consult to amend the Convention; failing progress, the other State may notify that it will cease applying the provisions on dividends, interest, royalties and other income, and those provisions will cease to have effect for resident companies six months after a public written notification. The general statutory rate calculation includes generally available percentage based deductions and excludes taxes applied only on distribution or to shareholders.
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.
Change in company tax rate may trigger treaty consultations and suspension of dividend, interest, royalty and other income provisions.
If a Contracting State reduces its general statutory rate of company tax below the threshold or exempts substantially all foreign source income, the States shall consult to amend the Convention; failing progress, the other State may notify that it will cease applying the provisions on dividends, interest, royalties and other income, and those provisions will cease to have effect for resident companies six months after a public written notification. The general statutory rate calculation includes generally available percentage based deductions and excludes taxes applied only on distribution or to shareholders.
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