Tax treaty definitions clarify key terms, scope of 'relevant' information, and law-applicability for information exchange. Article 4 prescribes key definitions for the Agreement, including territorial scope, Contracting Parties, competent authority, persons, companies, publicly traded companies, recognised stock exchanges, collective investment funds, 'tax', requesting/requested Party, 'information gathering measures' and 'information'. It requires a broad construction of 'relevant' information so that relevance need not be ascertainable until after receipt, and provides that undefined terms default to the domestic law meaning of the applying Party at the relevant time, with tax-law meanings prevailing.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Tax treaty definitions clarify key terms, scope of 'relevant' information, and law-applicability for information exchange.
Article 4 prescribes key definitions for the Agreement, including territorial scope, Contracting Parties, competent authority, persons, companies, publicly traded companies, recognised stock exchanges, collective investment funds, "tax", requesting/requested Party, "information gathering measures" and "information". It requires a broad construction of "relevant" information so that relevance need not be ascertainable until after receipt, and provides that undefined terms default to the domestic law meaning of the applying Party at the relevant time, with tax-law meanings prevailing.
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