DTAA general definitions set territorial scope, taxpayer status and competent authority roles governing treaty tax application. The Agreement defines territorial scope and key taxpayer concepts, including 'person', 'company', 'enterprise', 'enterprise of a Contracting State' and 'international traffic', ties institutional designations by naming each State's competent authority, and specifies that 'tax' excludes penalties while 'fiscal year' is defined per State; undefined terms are to be given the meaning they have under the domestic tax law of the Contracting State applying the Agreement.
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.
DTAA general definitions set territorial scope, taxpayer status and competent authority roles governing treaty tax application.
The Agreement defines territorial scope and key taxpayer concepts, including "person", "company", "enterprise", "enterprise of a Contracting State" and "international traffic", ties institutional designations by naming each State's competent authority, and specifies that "tax" excludes penalties while "fiscal year" is defined per State; undefined terms are to be given the meaning they have under the domestic tax law of the Contracting State applying the Agreement.
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