Residence-based personal scope applies to persons residing in one or both treaty states under the DTAA. Article 1 defines the Agreement's personal scope, providing that the DTAA applies to persons who are residents of one or both Contracting States, thereby determining who falls within the treaty's coverage. It also records that the Agreement was ratified and that domestic authorities have directed that its provisions be given effect under the relevant provisions of domestic tax law.
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 personal scope applies to persons residing in one or both treaty states under the DTAA.
Article 1 defines the Agreement's personal scope, providing that the DTAA applies to persons who are residents of one or both Contracting States, thereby determining who falls within the treaty's coverage. It also records that the Agreement was ratified and that domestic authorities have directed that its provisions be given effect under the relevant provisions of domestic tax law.
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