General definitions: territorial scope and tax terms clarified for bilateral double taxation agreement application and administration Article 3 sets general definitions for the bilateral tax agreement, defining territorial reach, covered taxes, and specific terms including person, company, enterprise, international traffic, competent authority, national, tax, and fiscal year. It provides that undefined terms are to be interpreted according to the meaning they have under the domestic tax law of the Contracting State applying the Agreement, with that tax-law meaning prevailing.
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General definitions: territorial scope and tax terms clarified for bilateral double taxation agreement application and administration
Article 3 sets general definitions for the bilateral tax agreement, defining territorial reach, covered taxes, and specific terms including person, company, enterprise, international traffic, competent authority, national, tax, and fiscal year. It provides that undefined terms are to be interpreted according to the meaning they have under the domestic tax law of the Contracting State applying the Agreement, with that tax-law meaning prevailing.
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