Tax treaty definitions clarify resident, taxable person, competent authority and fiscal year, with domestic law controlling undefined terms. Defines territorial scope, and key terms including person, company, enterprise, international traffic, competent authority, national, fiscal year, and tax (excluding penalties). States that undefined terms take their meaning under the domestic tax law of the applying Contracting State, with tax-law meanings prevailing over other domestic 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.
Tax treaty definitions clarify resident, taxable person, competent authority and fiscal year, with domestic law controlling undefined terms.
Defines territorial scope, and key terms including person, company, enterprise, international traffic, competent authority, national, fiscal year, and tax (excluding penalties). States that undefined terms take their meaning under the domestic tax law of the applying Contracting State, with tax-law meanings prevailing over other domestic meanings.
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