Entry into force of tax convention triggers phased application to aircraft income and other income under specified territorial rules. The Convention enters into force upon the exchange of instruments of ratification, with commencement staggered by income category and territorial rules: aircraft operation income follows period-specific treatment tied to prior fiscal/accounting years, while other income categories take effect from the first applicable fiscal or calendar period, taxable period, or assessment date following that exchange. Distinct commencement rules apply to taxes on movable capital, wages and pensions, commercial and industrial profits, income from immovable property, professional income and general income tax, and to corresponding supplementary levies.
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.
Entry into force of tax convention triggers phased application to aircraft income and other income under specified territorial rules.
The Convention enters into force upon the exchange of instruments of ratification, with commencement staggered by income category and territorial rules: aircraft operation income follows period-specific treatment tied to prior fiscal/accounting years, while other income categories take effect from the first applicable fiscal or calendar period, taxable period, or assessment date following that exchange. Distinct commencement rules apply to taxes on movable capital, wages and pensions, commercial and industrial profits, income from immovable property, professional income and general income tax, and to corresponding supplementary levies.
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