Residence-based scope: Agreement applies to persons resident in one or both Contracting States, defining treaty applicability. Article 1 establishes the personal scope of the Agreement: it applies to persons who are residents of one or both Contracting States, thereby defining treaty applicability by reference to residency for purposes of the avoidance of double taxation 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: Agreement applies to persons resident in one or both Contracting States, defining treaty applicability.
Article 1 establishes the personal scope of the Agreement: it applies to persons who are residents of one or both Contracting States, thereby defining treaty applicability by reference to residency for purposes of the avoidance of double taxation and prevention of fiscal evasion.
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