Tax treaty definitions establish territorial scope, key taxpayer categories, international traffic, and competent authorities for treaty application. Article 3 defines key treaty terms for the India-Japan DTAA: territorial definitions of Japan and India for tax jurisdiction; 'tax' as the domestic taxes of the Contracting States; 'person' and 'company' to include individuals, bodies corporate and entities treated as corporate; resident enterprises and 'nationals' as determined under each State's law; 'international traffic' limited to transport by an enterprise of a Contracting State except when operated solely within the other State; and each State's designated competent authority. Undefined terms default to their domestic 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.
Tax treaty definitions establish territorial scope, key taxpayer categories, international traffic, and competent authorities for treaty application.
Article 3 defines key treaty terms for the India-Japan DTAA: territorial definitions of Japan and India for tax jurisdiction; "tax" as the domestic taxes of the Contracting States; "person" and "company" to include individuals, bodies corporate and entities treated as corporate; resident enterprises and "nationals" as determined under each State's law; "international traffic" limited to transport by an enterprise of a Contracting State except when operated solely within the other State; and each State's designated competent authority. Undefined terms default to their domestic tax-law meanings.
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