Tax treaty definitions clarify residence, company, enterprise, competent authority and fiscal year for treaty application. Article 3 defines territorial scope and key treaty terms: India and Georgia territories and maritime zones; 'person' (including individuals and companies); 'company' as bodies corporate; 'enterprise' and 'enterprise of a Contracting State' tied to residence; 'international traffic' for transport by ships and aircraft; the competent authority designations; 'national' by citizenship or legal status; treatment of 'tax' excluding penalties; and that undefined terms take their meaning from the applying State's 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.
Tax treaty definitions clarify residence, company, enterprise, competent authority and fiscal year for treaty application.
Article 3 defines territorial scope and key treaty terms: India and Georgia territories and maritime zones; "person" (including individuals and companies); "company" as bodies corporate; "enterprise" and "enterprise of a Contracting State" tied to residence; "international traffic" for transport by ships and aircraft; the competent authority designations; "national" by citizenship or legal status; treatment of "tax" excluding penalties; and that undefined terms take their meaning from the applying State's tax law.
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