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 ... Summary
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.
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