DTAA definitions set scope of residency, taxable person, and tax terms for bilateral treaty application today. Article 3 defines key terms for treaty application: territorial definitions of the Contracting States; 'person' to include individuals, companies and other taxable entities; 'company' as any corporate body for tax purposes; 'enterprise' as carried on by a resident; 'national' to include natural and legal persons under domestic law; 'international traffic' limited to certain ship or aircraft operations; designation of each State's competent authority; 'tax' limited to Finnish or Indian taxes excluding penalties; and fiscal year defined per each State's domestic law. Paragraph 2 makes undefined terms subject to the applying State's tax-law meanings.
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.
DTAA definitions set scope of residency, taxable person, and tax terms for bilateral treaty application today.
Article 3 defines key terms for treaty application: territorial definitions of the Contracting States; "person" to include individuals, companies and other taxable entities; "company" as any corporate body for tax purposes; "enterprise" as carried on by a resident; "national" to include natural and legal persons under domestic law; "international traffic" limited to certain ship or aircraft operations; designation of each State's competent authority; "tax" limited to Finnish or Indian taxes excluding penalties; and fiscal year defined per each State's domestic law. Paragraph 2 makes undefined terms subject to the applying State's tax-law meanings.
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