Tax treaty definitions set scope of residence, national status and competent authority, determining applicable tax rules. Article 3 defines key terms for the Canada-India DTAA: territorial scope of Canada and India; 'Contracting State', 'person', 'company', and 'enterprise' as including residents and taxable entities; the 'competent authority' of each state; 'national' covering individuals and legal persons under domestic law; 'tax' as Canadian or Indian tax excluding penalties; and 'international traffic' for ships and aircraft, with undefined terms to take their meaning from the domestic law of the Contracting State applying the Agreement.
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 treaty definitions set scope of residence, national status and competent authority, determining applicable tax rules.
Article 3 defines key terms for the Canada-India DTAA: territorial scope of Canada and India; 'Contracting State', 'person', 'company', and 'enterprise' as including residents and taxable entities; the 'competent authority' of each state; 'national' covering individuals and legal persons under domestic law; 'tax' as Canadian or Indian tax excluding penalties; and 'international traffic' for ships and aircraft, with undefined terms to take their meaning from the domestic law of the Contracting State applying the Agreement.
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