Tax treaty definitions set territorial scope and interpretive rules for tax terms, giving domestic law meanings primacy. Article 3 defines territorial scope and core terms for the India-Estonia tax treaty: 'India' and 'Estonia' include territorial and maritime zones; 'person', 'company', and 'enterprise' are specified; 'enterprise of a Contracting State' and 'international traffic' are distinguished. The Article names each State's competent authority, defines 'national', limits the definition of 'tax' to exclude penalties, and sets the respective fiscal year references. It further provides that undefined terms are to be interpreted according to the domestic tax law of the Contracting State applying the Agreement.
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Tax treaty definitions set territorial scope and interpretive rules for tax terms, giving domestic law meanings primacy.
Article 3 defines territorial scope and core terms for the India-Estonia tax treaty: "India" and "Estonia" include territorial and maritime zones; "person", "company", and "enterprise" are specified; "enterprise of a Contracting State" and "international traffic" are distinguished. The Article names each State's competent authority, defines "national", limits the definition of "tax" to exclude penalties, and sets the respective fiscal year references. It further provides that undefined terms are to be interpreted according to the domestic tax law of the Contracting State applying the Agreement.
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