Tax treaty definitions clarify residence, entity status, international traffic, and competent authority roles. Article 3 defines key terms for the India-Russia tax convention: territorial scope of each State, the meanings of 'person,' 'company,' 'enterprise,' 'national,' and 'international traffic,' and that 'tax' excludes penalties and interest. It specifies each State's fiscal year start and designates the competent authority for treaty administration. Terms not defined in the Agreement take their meaning from the domestic law of the Contracting State applying the Agreement with respect to the covered taxes.
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Provisions expressly mentioned in the judgment/order text.
Tax treaty definitions clarify residence, entity status, international traffic, and competent authority roles.
Article 3 defines key terms for the India-Russia tax convention: territorial scope of each State, the meanings of "person," "company," "enterprise," "national," and "international traffic," and that "tax" excludes penalties and interest. It specifies each State's fiscal year start and designates the competent authority for treaty administration. Terms not defined in the Agreement take their meaning from the domestic law of the Contracting State applying the Agreement with respect to the covered taxes.
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