Tax definitions under the DTAA clarify residency, entity status, and international traffic for treaty application. The Convention defines key terms for treaty application: United Kingdom (including continental shelf areas), tax (United Kingdom or Indian as relevant), 'person', 'company', 'enterprise', and 'fiscal year' (linked to India's 'previous year'). It identifies the competent authority, defines international traffic by reference to place of effective management with a domestic exception, and treats 'Government' to include sub national authorities. Undefined terms take their meaning from the applying State's domestic tax law unless context dictates otherwise.
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 definitions under the DTAA clarify residency, entity status, and international traffic for treaty application.
The Convention defines key terms for treaty application: United Kingdom (including continental shelf areas), tax (United Kingdom or Indian as relevant), "person", "company", "enterprise", and "fiscal year" (linked to India's "previous year"). It identifies the competent authority, defines international traffic by reference to place of effective management with a domestic exception, and treats "Government" to include sub national authorities. Undefined terms take their meaning from the applying State's domestic tax law unless context dictates otherwise.
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