General Definitions in the DTAA define residency, national status, enterprises, tax scope and competent authority roles. Definitions specify territorial scope, taxable persons, and governing authorities under the DTAA: India and Nepal are defined territorially; 'person', 'company' and 'enterprise of a Contracting State' are defined by tax treatment and residence; 'international traffic' is limited to transport by ships or aircraft of an enterprise of a Contracting State except for domestic operations in the other State. The Article names each State's competent authority, restricts the term tax to exclude penalties, aligns fiscal years to national conventions, and directs that undefined terms take their domestic tax law meanings when applied.
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Provisions expressly mentioned in the judgment/order text.
General Definitions in the DTAA define residency, national status, enterprises, tax scope and competent authority roles.
Definitions specify territorial scope, taxable persons, and governing authorities under the DTAA: India and Nepal are defined territorially; "person", "company" and "enterprise of a Contracting State" are defined by tax treatment and residence; "international traffic" is limited to transport by ships or aircraft of an enterprise of a Contracting State except for domestic operations in the other State. The Article names each State's competent authority, restricts the term tax to exclude penalties, aligns fiscal years to national conventions, and directs that undefined terms take their domestic tax law meanings when applied.
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