Tax treaty definitions set scope for residency, company, enterprise, and competent authority, shaping cross-border taxation. The Agreement defines territorial scope and key terms-such as 'person', 'national', 'company', 'enterprise', 'international traffic', 'tax' and 'competent authority'-to determine treaty coverage and administration; it states that undefined terms take their meaning from the applying Contracting State's tax law, with tax-law meanings prevailing over other domestic-law meanings, and excludes penalties from the definition of tax.
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 set scope for residency, company, enterprise, and competent authority, shaping cross-border taxation.
The Agreement defines territorial scope and key terms-such as "person", "national", "company", "enterprise", "international traffic", "tax" and "competent authority"-to determine treaty coverage and administration; it states that undefined terms take their meaning from the applying Contracting State's tax law, with tax-law meanings prevailing over other domestic-law meanings, and excludes penalties from the definition of tax.
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