Interpretation of the phrase “may be taxed”: Waiting for finality

One of the main purposes of a Double Taxation Avoidance Agreements (DTAA) is to avoid double taxation. This is made clear in the preamble, itself, which states that the treaty partner countries are entering in the agreement to avoid double taxation and to prevent fiscal evasion.

from taxmann.com News https://www.taxmann.com/topstories/222330000000020607/interpretation-of-the-phrase-“may-be-taxed”-waiting-for-finality.aspx