Tax treaty definitions clarify territorial scope, key taxpayer categories and applicable domestic tax-law meanings. Article 3 provides uniform definitions for the India-Georgia DTAA, specifying territorial scope for each State, and defining key terms including 'person,' 'company,' 'enterprise,' 'international traffic,' 'competent authority,' and 'national.' It defines 'tax' for treaty purposes excluding penalties, sets the respective fiscal year references for India and Georgia, and requires that any term not defined in the Agreement be construed according to the domestic tax law of the Contracting State applying the Agreement, with tax-law meanings prevailing.
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Provisions expressly mentioned in the judgment/order text.
Article 3 provides uniform definitions for the India-Georgia DTAA, specifying territorial scope for each State, and defining key terms including "person," "company," "enterprise," "international traffic," "competent authority," and "national." It defines "tax" for treaty purposes excluding penalties, sets the respective fiscal year references for India and Georgia, and requires that any term not defined in the Agreement be construed according to the domestic tax law of the Contracting State applying the Agreement, with tax-law meanings prevailing.
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