Term definition in tax treaty agreements: contractual definitions prevail, otherwise Act definitions and government explanations apply. Insertion of Explanation 4 to section 90 clarifies that where a term used in an agreement under subsection (1) is defined in the agreement, that ... Summary
Term definition in tax treaty agreements: contractual definitions prevail, otherwise Act definitions and government explanations apply.
Insertion of Explanation 4 to section 90 clarifies that where a term used in an agreement under subsection (1) is defined in the agreement, that contractual definition governs; if the term is not defined in the agreement but is defined in the Act, the statutory definition and any explanation by the Central Government govern.
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