General Definitions in DTAA clarify residence, taxable persons, and scope of taxes, guiding interpretation between Contracting States. General Definitions establish key terms for the Convention: territorial scope, 'person' and 'company', 'enterprise' as an operation by a resident, 'international traffic' limited to cross-border transport by resident enterprises, designation of each Contracting State's competent authority, the meaning of 'national', and the applicable definitions of 'fiscal year' and 'tax'; undefined terms are to be interpreted by the domestic law of the applying Contracting State for the taxes covered.
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Provisions expressly mentioned in the judgment/order text.
General Definitions in DTAA clarify residence, taxable persons, and scope of taxes, guiding interpretation between Contracting States.
General Definitions establish key terms for the Convention: territorial scope, "person" and "company", "enterprise" as an operation by a resident, "international traffic" limited to cross-border transport by resident enterprises, designation of each Contracting State's competent authority, the meaning of "national", and the applicable definitions of "fiscal year" and "tax"; undefined terms are to be interpreted by the domestic law of the applying Contracting State for the taxes covered.
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