Tax treaty definitions determine persons, companies, taxes and fiscal year scopes under the treaty for taxation. Article 3 defines core treaty terms: 'person' includes individuals and taxable entities; 'company' means bodies corporate or equivalent tax entities; 'enterprise' and 'enterprise of a Contracting State' are specified; 'international traffic' is transport by ships or aircraft of an enterprise of a Contracting State except when operated solely between places in the other State. The Article names each State's competent authority, defines 'national' by domestic law, limits 'tax' to Indian or Norwegian taxes excluding penalties, and fixes each State's fiscal year convention.
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 determine persons, companies, taxes and fiscal year scopes under the treaty for taxation.
Article 3 defines core treaty terms: "person" includes individuals and taxable entities; "company" means bodies corporate or equivalent tax entities; "enterprise" and "enterprise of a Contracting State" are specified; "international traffic" is transport by ships or aircraft of an enterprise of a Contracting State except when operated solely between places in the other State. The Article names each State's competent authority, defines "national" by domestic law, limits "tax" to Indian or Norwegian taxes excluding penalties, and fixes each State's fiscal year convention.
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