Tax treaty definitions clarify residency, taxable persons and territorial scope for applying cross-border tax rules. The Article supplies the Convention's foundational definitions: territorial scope for India and France, and key terms such as person, company, enterprise, competent authority, national, international traffic, fiscal year, and tax. It further provides that any term not defined in the Convention takes its meaning from the domestic tax law of the Contracting State applying the Convention.
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Provisions expressly mentioned in the judgment/order text.
Tax treaty definitions clarify residency, taxable persons and territorial scope for applying cross-border tax rules.
The Article supplies the Convention's foundational definitions: territorial scope for India and France, and key terms such as person, company, enterprise, competent authority, national, international traffic, fiscal year, and tax. It further provides that any term not defined in the Convention takes its meaning from the domestic tax law of the Contracting State applying the Convention.
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