Termination of tax treaty: diplomatic notice ends the convention, with a transition period before taxation changes. Either Contracting State may terminate the tax convention by giving notice through diplomatic channels and the Convention terminates on the date of that notification. The Convention provides a transition period after notice: withholding tax rules cease to apply only for amounts paid or credited after the expiry of the transition period, while other taxes are affected for taxable years beginning on or after the expiry of that period.
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.
Termination of tax treaty: diplomatic notice ends the convention, with a transition period before taxation changes.
Either Contracting State may terminate the tax convention by giving notice through diplomatic channels and the Convention terminates on the date of that notification. The Convention provides a transition period after notice: withholding tax rules cease to apply only for amounts paid or credited after the expiry of the transition period, while other taxes are affected for taxable years beginning on or after the expiry of that period.
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