Treaty definitions clarify territorial scope, taxpayer categories, and competent authority roles for bilateral tax relief. Article 3 supplies the Convention's operative definitions: territorial scope of India and France (including territorial seas, airspace and maritime zones); categories of taxable entities and persons including company, national and enterprise of a Contracting State; competent authority; international traffic; fiscal year (India: previous year; France: calendar year); and the term tax as applicable. It also provides that any term not defined in the Convention shall have, unless context requires otherwise, the meaning assigned by the domestic law of the Contracting State applying the Convention for the taxes to which the Convention applies.
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.
Treaty definitions clarify territorial scope, taxpayer categories, and competent authority roles for bilateral tax relief.
Article 3 supplies the Convention's operative definitions: territorial scope of India and France (including territorial seas, airspace and maritime zones); categories of taxable entities and persons including company, national and enterprise of a Contracting State; competent authority; international traffic; fiscal year (India: previous year; France: calendar year); and the term tax as applicable. It also provides that any term not defined in the Convention shall have, unless context requires otherwise, the meaning assigned by the domestic law of the Contracting State applying the Convention for the taxes to which the Convention applies.
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