Tax treaty definitions define residency, tax scope, allocation of taxing rights, and competent authority roles under the DTAA. Article 3 provides definitions for territorial scope, the meaning of tax (limited to taxes covered and excluding penalties), and key categories: person, ... Summary
Tax treaty definitions define residency, tax scope, allocation of taxing rights, and competent authority roles under the DTAA.
Article 3 provides definitions for territorial scope, the meaning of tax (limited to taxes covered and excluding penalties), and key categories: person, company, enterprise, and national. It defines international traffic by reference to place of effective management and operation of transport, designates each State's competent authority, and requires that terms not defined in the Agreement be interpreted according to the domestic law of the Contracting State applying the Agreement.
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