Tax treaty definitions determine residency, taxable persons and competent authorities, shaping cross-border tax allocation and fiscal year rules. Article 3 defines treaty terms: territorial meanings of India and Ethiopia; 'Contracting State' designations; 'person', 'company', 'enterprise', and 'enterprise of a Contracting State'; the scope of 'international traffic'; identification of each State's competent authority; the meaning of 'national'; the definition of 'tax' excluding penalties; and each State's fiscal year for application.
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Provisions expressly mentioned in the judgment/order text.
Tax treaty definitions determine residency, taxable persons and competent authorities, shaping cross-border tax allocation and fiscal year rules.
Article 3 defines treaty terms: territorial meanings of India and Ethiopia; "Contracting State" designations; "person", "company", "enterprise", and "enterprise of a Contracting State"; the scope of "international traffic"; identification of each State's competent authority; the meaning of "national"; the definition of "tax" excluding penalties; and each State's fiscal year for application.
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