General definitions in DTAA define residence, taxable persons and competent authority roles governing treaty application. Article 3 defines key treaty terms including territorial scope, persons and entities covered, enterprise, international traffic, national, year of ... Summary
General definitions in DTAA define residence, taxable persons and competent authority roles governing treaty application.
Article 3 defines key treaty terms including territorial scope, persons and entities covered, enterprise, international traffic, national, year of assessment and fiscal year, and designates each Party's competent authority and the applicable meaning of "tax." It also provides that undefined terms take their meaning from the domestic law of the applying Contracting Party for the taxes to which the Agreement applies, with tax-law meanings prevailing over other domestic-law meanings.
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