Tax treaty definitions delimit residence, taxable persons, enterprises, and competent authority roles affecting cross-border taxation. Defines territorial scope of each Contracting State and core treaty terms: person, company, enterprise, and 'enterprise of a Contracting State' by residence; defines 'international traffic' by operation of ships or aircraft; designates each State's competent authority and defines 'national'; limits the meaning of 'tax' to covered taxes excluding penalties; prescribes each State's fiscal year; and provides that undefined terms are to be construed by reference to the applying State's domestic tax law.
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.
Defines territorial scope of each Contracting State and core treaty terms: person, company, enterprise, and "enterprise of a Contracting State" by residence; defines "international traffic" by operation of ships or aircraft; designates each State's competent authority and defines "national"; limits the meaning of "tax" to covered taxes excluding penalties; prescribes each State's fiscal year; and provides that undefined terms are to be construed by reference to the applying State's domestic tax law.
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