Tax treaty definitions determine scope of taxation, residence and competent authority roles between the Contracting States. Article 3 establishes treaty definitions that fix territorial scope, identify Contracting States, and define key terms including person, company, enterprise, enterprise of a Contracting State, international traffic, tax (limited to covered taxes excluding penalties), competent authority, national, and year of income; it further provides that undefined terms take their meaning from the domestic tax law of the applying Contracting State.
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 determine scope of taxation, residence and competent authority roles between the Contracting States.
Article 3 establishes treaty definitions that fix territorial scope, identify Contracting States, and define key terms including person, company, enterprise, enterprise of a Contracting State, international traffic, tax (limited to covered taxes excluding penalties), competent authority, national, and year of income; it further provides that undefined terms take their meaning from the domestic tax law of the applying Contracting State.
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