Residency doctrine determines treaty application: convention covers persons resident in one or both contracting states. The Convention applies to persons who are residents of one or both Contracting States, making residency the primary connecting factor for treaty entitlement. The Central Government has given effect to the Convention under domestic tax statute powers, incorporating its framework for avoidance of double taxation and prevention of fiscal evasion into national 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.
Residency doctrine determines treaty application: convention covers persons resident in one or both contracting states.
The Convention applies to persons who are residents of one or both Contracting States, making residency the primary connecting factor for treaty entitlement. The Central Government has given effect to the Convention under domestic tax statute powers, incorporating its framework for avoidance of double taxation and prevention of fiscal evasion into national law.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 
Join Channel
TaxTMI 
