Tax treaty definitions determine residency, taxable scope, competent authority roles and fiscal year alignment for treaty application. Defines key treaty terms: Contracting State scope, territorial reach, and core status concepts including 'person,' 'company,' 'enterprise,' 'enterprise of a Contracting State,' and 'international traffic.' Designates each State's competent authority and defines 'national,' 'tax' (excluding penalties and default amounts) and 'fiscal year,' and requires that undefined terms be interpreted by the domestic tax law of the applying Contracting State with tax-law meanings prevailing.
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 residency, taxable scope, competent authority roles and fiscal year alignment for treaty application.
Defines key treaty terms: Contracting State scope, territorial reach, and core status concepts including "person," "company," "enterprise," "enterprise of a Contracting State," and "international traffic." Designates each State's competent authority and defines "national," "tax" (excluding penalties and default amounts) and "fiscal year," and requires that undefined terms be interpreted by the domestic tax law of the applying Contracting State with tax-law meanings prevailing.
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