Tax treaty definitions clarifying territorial scope, taxable person concepts, competent authorities and undefined-term rule. Article 3 establishes core treaty definitions: territorial scope of India and Poland; the meaning of 'Contracting State'; the definition of tax excluding penalties; and meanings of 'person,' 'company,' 'enterprise,' 'national,' 'international traffic,' and the competent authority. It provides that terms not defined in the Agreement have the meaning they possess under the domestic law of the applying Contracting State, and specifies the fiscal year definition for India.
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 clarifying territorial scope, taxable person concepts, competent authorities and undefined-term rule.
Article 3 establishes core treaty definitions: territorial scope of India and Poland; the meaning of "Contracting State"; the definition of tax excluding penalties; and meanings of "person," "company," "enterprise," "national," "international traffic," and the competent authority. It provides that terms not defined in the Agreement have the meaning they possess under the domestic law of the applying Contracting State, and specifies the fiscal year definition for India.
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