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 ... Summary
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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