Definitions establish territory, person, company, enterprise and tax scope for applying the double tax agreement. Definitions fix the Agreement's operative terms: territory aligns with Article 2; person, company and enterprise are given tax meanings; international traffic is carriage by ships or aircraft of an enterprise of a territory except when solely within the other territory; competent authority means the finance minister or authorised representative of each territory; tax is limited to the covered taxes and excludes penalties; fiscal year is set by each territory's financial year; undefined terms take their meaning from the domestic tax law of the applying territory.
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.
Definitions establish territory, person, company, enterprise and tax scope for applying the double tax agreement.
Definitions fix the Agreement's operative terms: territory aligns with Article 2; person, company and enterprise are given tax meanings; international traffic is carriage by ships or aircraft of an enterprise of a territory except when solely within the other territory; competent authority means the finance minister or authorised representative of each territory; tax is limited to the covered taxes and excludes penalties; fiscal year is set by each territory's financial year; undefined terms take their meaning from the domestic tax law of the applying territory.
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