Article 31 - Termination - Poland

ARTICLE 31 TERMINATION This Agreement shall remain in force indefinitely but either of the Contracting States may, on or before the thirtieth day of June in any calendar year beginning after the expiration of a period of five years from the date of its entry into force, give the other Contracting State through diplomatic channels, written notice of termination and, in such event, this Agreement shall cease to have effect: (a) in India, in respect of income arising in any previous year beginning on or after the 1st day of April next following the calendar year in which the notice is given; (b) in Poland, in respect of income arising in any year of income beginning on or after the 1st day of January next following the calendar year in which the notice of termination is given. SECTION 90 OF THE INCOME-TAX ACT, 1961 - DOUBLE TAXATION AGREEMENT -AGREEMENT FOR AVOIDANCE OF DOUBLE TAXATION AND PREVENTION OF FISCAL EVASION WITH FOREIGN COUNTRIES - POLAND NOTIFICATION NO.47/2014 [F.NO.501/08/1979-FTD-I], DATED 24-9-2014 Whereas, a Protocol (hereinafter referred to as the said Protocol) as set out in the Annexure, was entered into between the Government of the Republic of India and the Government of the Polish People's Republic amending the Agreement between the Government of the Republic of India and the Government of the Polish People's Republic for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income that was signed at Warsaw on the 21st day of June, 1989; And whereas, the date of entry into force of the said Protocol is the 1st day of June, 2014, being the thirtieth day after the date of receipt of latter of the notifications of completion of the procedures as required by the respective laws for entry into force of the said Protocol, in accordance with paragraph 1 of article 17 of the said Protocol; And whereas, sub-paragraph (a) of paragraph 1 of article 17 of the said Protocol provides that the provisions of the said Agreement shall have effect in India in respect of taxes withheld at source to amounts of income derived on or after the first day of the fiscal year next following the year in which the Protocol enters into force and in respect of other taxes on income to amounts of income derived in any fiscal year beginning on or after the first day of the fiscal year next following the year in which the Protocol enters into force; Now, therefore, in exercise of the powers conferred by section 90 of the Income-tax Act, 1961 (43 of 1961), the Central Government hereby directs that all the provisions of the said Protocol amending the agreements between the Government of the Republic of India and the Government of Polish People's Republic for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, as set out in the Annexure hereto, shall be given effect to in the Union of India with effect from the first day of April, 2015, being the first day of the fiscal year next following the year in which the Protocol enters into force.