Definition of national and person in DTAA clarifies cross-border tax residency and entity treatment.

The Convention defines key operative terms for tax application, including territorial scope, national, person, company, enterprise of a Contracting State, international traffic, fiscal year definitions and each State's Competent authority. It provides an interpretive rule that undefined terms take the meaning given by the domestic tax law of the applying Contracting State at the relevant time, and that tax-law meanings prevail over other domestic law meanings unless the Convention's context requires otherwise.

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