Under international law, a treaty enters into force either on the date and in the manner specified by agreement between the parties, or, failing such specific agreement, as soon as consent to be bound by the treaty has been established.41 Tax treaties normally enter into force on the following terms:

‘Article 28: Entry into force

Each of the Contracting States shall notify to the other the completion of the procedures required by its law for the bringing into force of this Agreement. The Agreement shall enter into force on the date of the later of these notifications and shall thereupon have effect:

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