Tax treaty definitions set residency, taxable person, competent authority, and fiscal year rules shaping treaty application. Article 3 defines key terms for the India-Luxembourg tax treaty: territorial scopes of India and Luxembourg; 'Contracting State' references; definitions of person, company, enterprise, enterprise of a Contracting State, and international traffic; competent authorities as designated ministers or authorised representatives; national status for individuals and juridical persons; tax excluding penalties; and fiscal years (India from 1 April, Luxembourg from 1 January). It provides that undefined terms take their meaning from the domestic tax law of the applying Contracting State, with tax-law meanings prevailing.
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 set residency, taxable person, competent authority, and fiscal year rules shaping treaty application.
Article 3 defines key terms for the India-Luxembourg tax treaty: territorial scopes of India and Luxembourg; "Contracting State" references; definitions of person, company, enterprise, enterprise of a Contracting State, and international traffic; competent authorities as designated ministers or authorised representatives; national status for individuals and juridical persons; tax excluding penalties; and fiscal years (India from 1 April, Luxembourg from 1 January). It provides that undefined terms take their meaning from the domestic tax law of the applying Contracting State, with tax-law meanings prevailing.
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