Tax treaty definitions determine territorial scope, key terms and require domestic tax law meanings to govern treaty interpretation. The Convention defines territorial scope and essential tax terms-including Portugal, India, tax, person, company, enterprise, international traffic, competent authority, national, and fiscal year-with country specific formulations. It specifies each State's competent authority and links national status to nationality or domestic legal form. For any term not defined in the Convention, the meaning under the domestic tax law of the Contracting State applying the Convention governs, unless the context otherwise requires, with tax law meanings prevailing over other domestic 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 determine territorial scope, key terms and require domestic tax law meanings to govern treaty interpretation.
The Convention defines territorial scope and essential tax terms-including Portugal, India, tax, person, company, enterprise, international traffic, competent authority, national, and fiscal year-with country specific formulations. It specifies each State's competent authority and links national status to nationality or domestic legal form. For any term not defined in the Convention, the meaning under the domestic tax law of the Contracting State applying the Convention governs, unless the context otherwise requires, with tax law meanings prevailing over other domestic law meanings.
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