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Taxation

Is TRC Still Conclusive? Rethinking Treaty Entitlements

Harshita Dhinwa and Ram Sundar Singh Akela Introduction The Tax Residency Certificate was never a complete answer to the question of treaty entitlement on a proper reading of a treaty text and international law. It functioned primarily as a proof of jurisdiction, but over time, institutional practice elevated it to a substantial safeguard, which was […]