Tax treaty definitions clarify residency, taxable persons, competent authorities and fiscal year impacting cross-border tax application. The Agreement defines territorial scope, key taxable actors (person, company, enterprise), 'enterprise of a Contracting State,' 'international traffic,' competent authorities, 'national,' and fiscal years; it excludes penalties from the definition of 'tax' and requires undefined terms to take the meaning given by the applying Contracting State's tax law, with tax-law definitions prevailing over other domestic meanings.
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 residency, taxable persons, competent authorities and fiscal year impacting cross-border tax application.
The Agreement defines territorial scope, key taxable actors (person, company, enterprise), "enterprise of a Contracting State," "international traffic," competent authorities, "national," and fiscal years; it excludes penalties from the definition of "tax" and requires undefined terms to take the meaning given by the applying Contracting State's tax law, with tax-law definitions prevailing over other domestic meanings.
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