Tax treaty definitions clarify residence, competent authority, and recognised exchanges for treaty application and information exchange. The Agreement defines territorial scope, identifies competent authorities, and specifies core taxable subjects by reference to domestic tax treatment, including persons, companies, publicly traded companies, recognized stock exchanges, and collective investment funds. It also defines key terms for information exchange-tax, information, information gathering measures, requesting Party and requested Party-and provides that undefined terms take their contemporary meaning under the domestic law of the applying Contracting Party unless otherwise agreed.
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 clarify residence, competent authority, and recognised exchanges for treaty application and information exchange.
The Agreement defines territorial scope, identifies competent authorities, and specifies core taxable subjects by reference to domestic tax treatment, including persons, companies, publicly traded companies, recognized stock exchanges, and collective investment funds. It also defines key terms for information exchange-tax, information, information gathering measures, requesting Party and requested Party-and provides that undefined terms take their contemporary meaning under the domestic law of the applying Contracting Party unless otherwise agreed.
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