This Agreement shall enter into force on the first day of the second month after the later of the dates on which each of the Parties has notified the other in writing that the formalities constitutionally or otherwise required in their respective Party have been complied with. Upon the date of entry into force, it shall have effect:
- a)for criminal tax matters on that date; however, no earlier than January 1st, 2010; and
- b)for all other matters covered in Article 1 on that date; however, no earlier than January 1st, 2010, but only in respect of taxable periods beginning on or after that date or, where there is no taxable period, all charges to tax arising on or after that date.